“A bedrock principle underlying the First Amendment . . . is that the Government may not prohibit the expression of an idea simply because society find the idea itself offensive or disagreeable” (Texas v. Johnson, 491 U.S. 397 (1989). Concurrently, however, government has a reasonable duty to assure that open public meetings are orderly and safe. Increasing political polarization and efforts to gain control of grassroot governance has led to increasingly tense public school board meetings pressing against the boarders of where First Amendment expressions exceed the limits of decorum necessary for productive governmental conduct. Recent federal litigation provides guidance for school boards and their counsel to navigate the often narrow path between orderly meetings and unconstitutional free speech restrictions.