Constitutional means, additional restrictions can be put in place. IMO bipartisan legislation would be the proper way to go, but we'll just leave that to the scholars.
btw, I suggest you click on the first reference in the linked Wiki summary for more details.
Link: https://en.wikipedia.org/wiki/United_States_free_speech_exceptions#:~:text=Categories%20of%20speech%20that%20are,property%20law%2C%20true%20threats%2C%20false
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