if a tortious act of a federal employee causes damage, and the Tucker Act, which waives the immunity over claims arising out of contracts to which the federal government is a party. The Federal Tort Claims Act and the Tucker Act are not the broad waivers of sovereign immunity they might appear to be, as there are a number of statutory exceptions and judicially fashioned limiting doctrines applicable to both. Title 28 U.S.C. § 1331 confers federal question jurisdiction on district courts, but this statute has been held not to be a blanket waiver of sovereign immunity on the part of the federal government. In Federal tax refund cases filed by taxpayers (as opposed to third parties) against the United States, various courts have indicated that Federal sovereign immunity is waived under subsection (a)(1) of in conjunction with Internal Revenue Code section 7422 (), or under section 7422 in conjunction with subsection (a) of Internal Revenue Code section 6532 (). Further, in United States v. Williams, the U.S. Supreme Court held that in a case where an individual paid a federal tax under protest to remove a federal tax lien on her property where the tax she paid had been assessed against a third party, the waiver of sovereign immunity found in authorized her tax refund suit. Congress has also waived sovereign immunity for patent infringement claims under , but that statute balances this waiver with provisions that limit the remedies available to the patent holder. The government may not be enjoined from infringing a patent, and persons performing work for the government are immune both from liability and from injunction. Any recourse must be had only against the government in the United States Court of Federal Claims. In Advanced Software Design v. Federal Reserve Bank of St. Louis, the Federal Circuit expanded the interpretation of this protection to extend to private companies doing work not as contractors, but in which the government participates even indirectly. Section 702 of the Administrative Procedures Act provides a broad waiver of sovereign immunity for actions taken by administrative agencies. It provides that persons suffering a legal wrong because of an agency action are entitled to judicial review. State sovereign immunity in federal courts Early history and Eleventh Amendment In 1793, the Supreme Court held in Chisholm v. Georgia that Article III, § 2 of the United States Constitution, which granted diversity jurisdiction to