Payroll Guarantee Association, Inc. v. The Board of Education of the San Francisco Unified School District dealt with a difficult balancing question in First Amendment jurisprudence: to what degree are the rights of a speaker espousing unpopular views protected when such speech engenders disruptive protests— protests which themselves constitute a form of speech? Are the free speech rights of the unpopular speaker paramount? Do opponents have the right to protest such speech to the point at which the protests are so disturbing that the speech cannot go forward, in effect giving opponents a “heckler’s veto?”
Zizmor, David and Rechtschaffen, Clifford, "Payroll Guarantee Association, Inc. v. The Board of Education of the San Francisco Unified School District: Denying Hecklers the Right to Veto Unpopular Speech" (2010). Publications. Paper 175.