Bivens actions have been restricted by the Supreme Court when Congress has created other avenues for review and compensation. For example, the Court denied a Bivens action for procedural due process violations under the Social Security Act disability provisions because Congress had created an independent remedial scheme to restore benefits. [Schweiker v. Chilicky, 487 U.S. 412, 423 (1988)] Courts are careful not to extend Bivens where it is unnecessary or inappropriate. Some factors that may counsel hesitation in allowing Bivens action against federal actors include: conflict with federal fiscal policy; the existence of a comprehensive remedial scheme providing meaningful remedies created by Congress; and the unique structure and nature of the military. Id. at 421.