CA4: Feres doctrine barred Army NG officer’s § 1983 email search claim when he was deployed

Plaintiff was a Colonel in the North Carolina Army National Guard stationed in Kuwait, and he claimed that his email was unlawfully searched by another officer and forwarded around in violation of his Fourth Amendment rights. The Feres doctrine, requiring abstention of virtually any military related litigation, applies to § 1983 claims against the state National Guard, too. Aikens v. Ingram, 2016 U.S. App. LEXIS 1502 (4th Cir. Jan. 29, 2016).