The United States District Court for the District of Hawaii has held that damages are recoverable in a federal action under the Constitution against United States military personnel for violation of first amendment rights.
Butler v. United States, 365 F. Supp. 1035 (D. Hawaii 1973).
Susan K. Wright,
Constitutional Law - Federal Courts - Judicially Created Remedies - Damages for Violation of First Amendment,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol13/iss1/15