In Federal Housing Administration v. Burr, 309 U.S. 242 (1940), the plaintiff, an employee of the Federal Housing Administration ("FHA"), obtained a judgment from the Michigan Supreme Court that ordered the garnishment of federal funds in order to satisfy his claim. The Supreme Court found that Congress waived sovereign immunity for the FHA, and thus, it could sue and be sued; this extended to writs of execution against its property. Id. at 245-46. However, the only funds subject to garnishment were those already disbursed to the FHA. Id. at 250. The Court found that Congress's waiver of sovereign immunity for the FHA only extended to funds made available to it, and that funds not available to the FHA under the relevant statutes could not be garnished to pay the employee judgment creditor. Id. The U.S. Supreme Court set forth a presumption that the power to "sue and be sued" encompassed all civil processes and gave the federal corporation the same legal status as a private enterprise. 309 U.S. at 245. 60 S. Ct. at 490. The Supreme Court determined that such a presumption can only be overcome by a "grave interference" with a government function. Id. at 492. The Court further added: "Considerations of convenience, cost and efficiency which have been urged here are for Congress which, as we have said, has full authority to make such restrictions on the 'sue and be sued' clause as seem to it appropriate or necessary." Id.