In Feres v. United States (1950) 340 U.S. 135, the Supreme Court held that members of the armed forces may not bring tort lawsuits under the Federal Tort Claims Act (Tort Claims Act; 28 U.S.C. 2671 et seq.) for physical injuries that "arise out of or are in the course of activity incident to service." (Feres, supra, 340 U.S. at p. 146.) While the Feres case and its holding--that Congress did not intend to extend the remedies of the Tort Claims Act to servicemen where the injuries arise out of or are in the course of activity incident to service--concerned the Tort Claims Act, the rationale of Feres has been applied to a wide variety of statutory and constitutional claims. Thus, the "Feres doctrine" has a wider ambit than the Feres case. "Feres quite simply offers a template for construing a general statute as applied to active duty members of the military." (Estes v. Monroe (2004) 120 Cal.App.4th 1347, 1354 (Estes).) Moreover, "it is beyond question that the Feres doctrine generally applies to claims brought by National Guard members. " (Stauber v. Cline (9th Cir. 1988) 837 F.2d 395, 399.) Under Feres, a service member may not bring an action against the government or armed service personnel for injuries when such a legal action would require a civilian court to examine decisions regarding management, discipline, supervision, and control of the armed forces. While the Feres doctrine has been broadly construed as creating an immunity (Hodge v. Dalton (9th Cir. 1997) 107 F.3d 705, 710; Zaputil v. Cowgill (9th Cir. 2003) 335 F.3d 885, 887), other courts suggest "immunity" is not the proper term (Estes, supra, 120 Cal.App.4th at p. 1355). However, the result is the same: a member of the military is not permitted to recover in tort for injuries that arise out of or in the course of activity incident to service. (See Feres, supra, 340 U.S. at p. 146.)