KAREN NELSON MOORE, Circuit Judge. Plaintiff-Appellant Wayne G. Lovely appeals the order of the district court dismissing for lack of subject-matter jurisdiction Lovely’s claim brought under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. §§ 1346(b), 2671-2680. Lovely, a former student at the University of Dayton (“UD”) and member of the Army Reserve Officers’ Training Corps (“ROTC”), brought claims against Defendant-Appellee the United States of America and its agency, the United States Army ROTC Battalion at UD, for violation of Lovely’s rights under the Privacy Act, 5 U.S.C. § 552a, and for intentional infliction of emotional distress (“IIED”) under the FTCA. Lovely’s claims were based on actions taken by Lovely’s ROTC commander in relation to a UD disciplinary proceeding initiated against Lovely by another ROTC cadet. The district court dismissed Lovely’s IIED claim under the Feres doctrine, which precludes claims brought under the FTCA “for injuries to servicemen where the injuries arise out of or are in the course of activity incident to service.” Feres v. United States, 340 U.S. 135, 146 (1950).1 On appeal, Lovely argues that the district court erred in dismissing the IIED claim under Feres because Lovely was a UD student and not involved in any military activity at the time of his injury. For the reasons discussed below, we AFFIRM the judgment of the district court dismissing Lovely’s IIED claim as barred by the Feres doctrine.

MERRITT, Circuit Judge. The body of federal law governing Indian immunity from state taxation arises from the Commerce Clause, which grants to Congress the power “to regulate commerce with foreign Nations, and among the several States, and with the Indian Tribes,” and laws passed pursuant thereto. Under the Declaratory Judgment Act, 28 U.S.C. § 2201 (a federal court may “declare the rights” of the parties only in “a case of actual controversy”), the Keweenaw Bay Indian Community seeks (1) a broad declaration concerning its tax immunities under federal law, and (2) injunctive relief from Michigan’s policy of taxing transactions involving the Community and from Michigan’s reliance on an informal refund process to sort those immunities out on a case-by-case, transaction-by-transaction basis. Because the questions presented cover a myriad of hypothetical transactions and are too broad, too abstract, and unsupported by specific facts, the relief requested cannot be granted at this time. Lacking a specific factual context, the questions are not justiciable. The Community also appeals the District Court’s conclusion that the Community does not qualify as a “person” within the meaning of 42 U.S.C. § 1983 for purposes of its suit against members of the State Treasury department. Further factual development of the record is necessary before this issue can be fully resolved, and we remand the case for further proceedings on this issue.