Freedom of speech, as with other legal and civil rights, is an ideal, not an absolute. It has evolved tremendously within the US, arriving at a form we'd recognise currently only in the 1950s and 60s, about 60 years ago. The famous "shouting 'fire' in a crowded theatre" objection was raised in a case (Schenck) in free speech was found not to apply to anti-draft advocates during WWI, barely over a century ago.
And the US Supreme Court's "marketplace of ideas" standard is similarly quite problematic, owing far more to free-market fundamentalist advocacy than some doctrine of prevailing truth.
Turns out it was always more a bit of pro-free-market-fundamentalism propaganda than a pro-truth notion.
See Jill Gordon, “John Stuart Mill and the ‘Marketplace of Ideas’"
https://philpapers.org/rec/GORJSM
Or Stanley Ingber, “The Marketplace of Ideas: A legitimizing myth”.
https://scholarship.law.duke.edu/cgi/viewcontent.cgi?article... (PDF).