[444] The Court rejected the contention
that the doctrine of sovereign immunity should be relaxed as
inapplicable to suits for specific relief as distinguished from damage
suits, saying: "The Government, as representative of the community as a
whole, cannot be stopped in its tracks by any plaintiff who presents a
disputed question of property or contract right."[445]

CLASSIFICATION OF SUITS AGAINST OFFICERS

Suits against officers involving the doctrine of sovereign immunity have
been classified by Justice Frankfurter in a dissenting opinion into four
general groups. First, there are those cases in which the plaintiff
seeks an interest in property which belongs to the Government, or calls
"for an assertion of what is unquestionably official authority."[446]
Such suits, of course, cannot be maintained.[447] Second, cases in which
action adverse to the interests of a plaintiff is taken under an
unconstitutional statute or one alleged to be so. In general these suits
are maintainable.[448] Third, cases involving injury to a plaintiff
because the official has exceeded his statutory authority. In general
these suits are also maintainable.[449] Fourth, cases in which an
officer seeks immunity behind statutory authority or some other
sovereign command for the commission of a common law tort.[450] This
category of cases presents the greatest difficulties since these suits
can as readily be classified as falling into the first group if the
action directly or indirectly is one for specific performance or if the
judgment would affect the United States.

SUITS AGAINST GOVERNMENT CORPORATIONS

The multiplication of government corporations during periods of war and
depression has provided one motivation for limiting the doctrine of
sovereign immunity. In Keifer & Keifer _v._ Reconstruction Finance Corp.
and Regional Agricultural Credit Corp.,[451] the Court held that the
Government does not become a conduit of its immunity in suits against
its agents or instrumentalities merely because they do its work. Nor
does the creation of a government corporation confer upon it legal
immunity. Whether Congress endows a public corporation with governmental
immunity in a specific instance, is a matter of ascertaining the
Congressional will. Moreover, it has been held that waivers of
governmental immunity in the case of federal instrumentalities and
corporations should be construed liberally.[452] On the other hand,
Indian nations are exe