I understand how disruptive the audience can be. When I went to my niece’s graduation at a Catholic school I didnt hear her name called because someone behind me had one of those air horn cans. In the gym, with an air horn, it was loud and obnoxious. But to withhold a diploma isn’t right either. She earned her grades and the diploma fair and square. Seems like there has to be a balance and a way to be fair to conduct cermonies. But it seems like people nowadays don’t understand how to be formal and proper no matter where they are. Cheering is appropriate at a football game, not at a graduation.
I would withhold it for a stipulated period, say six months or a year.