It seems that in the 1600's some of the inhabitants of the Eastern shore went into court with complaints of "scandalous speeches" as with the complaints of Grace Robins and that of Mr. Cotton, the preacher. Here is another such case:
At a court held at Accomacke the 25th of September anno domni 1637 the complaint of John Waltam was heard. The text reads:
Upon the complaint of John Waltham against Anne Williamson the wife of RogerWilliamson and Anne Stephens the wife of Christopher Stephens for abusing him the said John Waltham and his wife by most vile and scandalous speeches. It is therefore thought fit and so ordered by this court that the said Anne Williamson and Anne Stephens shall be Duckt and ask the said John Waltham and his wife forgiveness in the public congregation.
Anne Williamson and Anne Stpehens were to be dunked and were ordered to make a public appology.
Walczyk, Frank V. Accomacke/Northampton 1632-1640, Book 1. Coram, NY: Peter's Row, 2003:66.