Does disruption violate free speech?

Erwin Chemerinsky co-writes for The Chronicle of Higher Education, Oct. 17, 2017

Accommodation is much less appropriate when some members of the campus are attempting to prevent others from exercising their rights. In such cases, heckler’s veto principles argue in favor of strong campus rebuffs of the claims of the disrupters. Otherwise, vulnerable or controversial opinions will never be expressible on a campus. And that would represent an abandonment of foundational principles of modern American higher education. Simply put, the right to speak does not include a right to use speech to keep others from speaking.