It depends on what they're yelling. Rude conduct potentially can garner a sanction, particularly if host management doesn't deal with it. The line in high school matches generally is comments directed at a particular player, rather than just yelling in general. But there's no requirement that the fans be silent during the serve.
It'd be like requiring fans to be silent during a free throw in basketball.
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Felix A. Madera
USAV Indoor National / Beach Zonal Referee
FIVB Qualified International Scorer
PAVO National Referee / Certified Line Judge/Scorer
WIAA/IHSA Volleyball Referee
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