“[n]o Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional injury suffered while in custody without a prior showing of physical injury.” 42 U.S.C. § 1997e(e). The defendants argue that the plaintiffs have failed to allege or make a showing of any physical injury in connection with their many claims of psychological stress. The precise scope of § 1997e(e) is not entirely clear. Many courts have held that § 1997e(e) does not necessarily bar an inmate’s right to vindicate certain types of constitutional claims. See, e.g., Canell v. Lightner, 143 F.3d 1210, 1213 (9th Cir.1998) (stating that § 1997e(e) is not applicable to First Amendment claims); Amaker v. Haponik, 1999 WL 76798, at *7 (S.D.N.Y. Feb.17, 1999) (<HOLDING>); Mason v. Schriro, 45 F.Supp.2d 709, 720
holding that the court of claims did not have jurisdiction over plaintiffs first amendment claim of improper removal holding that  1997ee did not bar plaintiffs first amendment claims holding that a law did not violate the first amendment because it did not burden the exchange of ideas and noting most laws restricting a states initiative process would not implicate the first amendment holding that the court of claims did have jurisdiction over plaintiffs statutory claim for back pay including arguments based on the first amendment holding that  1997ee is not applicable to plaintiffs first amendment claims because the statutory section applies to situations where the underlying claim involves an injury to a prisoners physical wellbeing