Can a Public Body Censure Its Members Without Raising First Amendment Concerns?

A public body censures one of its members who had been criticizing the body, filing lawsuits against the body, and accusing the body of not complying with state law.  The public body then censures the member. The member claims that the censure was a retaliatory act against his critical speech. This scenario forms the basis of the case, Houston Community College System v. Wilson, that the Supreme Court will review this term.