When I do reference checks, nowadays I specifically ask if they "shouted, angrily" or otherwise "demeaned employees verbally" to make it clear that a raised voice, per se, isn't necessarily a disqualifier.

I was turned down for a few key job transfers into a prestigious corporate research department because the gatekeeper said I had "yelled" at somebody before. The conversation in question was "heated" and I certainly pushed hard, but it certainly wasn't anything out of line with what I grew up with. However, I've reprogrammed my entire way of interacting since coming to California, as I found that a surprisingly large number of people will just shut you out otherwise.