S1983, Military
S1983 Fourth Amendment claim for monitoring national guardsman's email barred by military abstention, as the harm was incident to military service.
http://www.ca4.uscourts.gov/Opinions/Published/142419.P.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.