LEGAL PHASES OF COOPERATIVE ASSOCIATIONS 71 
Independent of a statutory provision entitling a cooperative as- 
sociation to the remedy of specific performance, will courts of equity 
thus compel members of cooperative associations to perform their 
contracts ? The fundamental rule with respect to this matter is that 
no one is entitled to a decree for specific performance, an injunc- 
tion, or other equitable relief where the remedy at law is plain, ade- 
quate, and complete. In general, courts of equity will refuse to 
grant a decree for specific performance or an injunction if com- 
pensation in money for the breach of the contract would consti- 
tute full and complete satisfaction. In the case of contracts in- 
volving personal property which can be easily purchased in the 
open market, a decree for specific performance will not as a general 
rule be granted. If a cooperative association is restricted, by the 
statute under which it is formed, by its charter, or by its contract, 
to dealing only with its members, it could not legally buy products to 
take the place of those which its members refused to deliver, and 
this fact has been referred to in some instances by the courts as 
constituting a reason why an association was entitled to have its 
contract with a member performed. 94 
Even though there is no provision in the law of a State specifically 
entitling an association to the remedies of specific performance and 
injunction against its members, the courts in some instances have 
held that associations were entitled to both of these remedies. 95 
Although most of the cases that have come before the courts in- 
volving the right of an association to the remedy of injunction or 
specific performance or both have involved the purchase-and-sale 
form of contract, the courts have enforced agency contracts by these 
remedies. 96 
Associations formed in one State have frequently been held entitled 
to the remedies of injunction and specific performance in suits 
brought in other States. 97 
Outside the field of cooperation, the courts have upheld the right 
of commercial concerns to the remedies of specific performance and 
injunction with respect to oil, 98 tomatoes, 99 and pineapples, 1 where 
it appeared that the products named could not be easily obtained 
in the open market. Some courts will refuse to decree the specific 
performance of a contract while enjoining the delinquent party 
from disposing of the products involved to third persons. Thus, 
the Supreme Court of Washington, independent of statute, in a 
cooperative case refused under the general principles of equity to 
decree the specific performance of the contract on the ground that 
94 Oregon Growers' Co-op. Ass'n v. Lentz, 107 Or. 561, 212 P. 811 ; Bishop v. Alabama 
Farm Bureau Cotton Ass'n, Ala. , 110 So. 711 ; Manchester Dairy System, 
Inc., v. Hayward, 82 N. H. 193, 132 A. 12 ; Dark Tobacco Growers' Co-op. Ass'n v. 
Dunn et al., 150 Tenn. 614, 266 S. W. 308 ; Kansas Wheat Growers' Ass'n v. Schulte, 
113 Kan. 672, 216 P. 311. 
95 Etephant Butte Alfalfa Ass'n v. Rouault, N. M. , 262 P. 185 ; Manchester 
Dairy System, Inc., v. Hayward, 82 N. H. 193, 132 A. 12. 
90 Elephant Butte Alfalfa Ass'n v. Rouault, N. M. , 262 P. 185 ; Elmore v. 
Maryland & Virginia Milk Producers' Ass'n, 145 Va. 42, 134 S. E. 472. 
97 Dark Tobacco Growers' Co-op. Ass'n v. Dunn, 150 Tenn. 614, 266 S. W. 308 ; Brown 
v. Staple Cotton Co-op. Ass'n, 132 Miss. 859, 96 So. 849 ; Elephant Butte Alfalfa Ass'n v. 
Rouault, N. M. . 262 P. 185 ; Manchester Dairy System, Inc., v . Hayward, 82 
N. H. 193, 132 A. 12 ; Nebraska Wheat Growers' Ass'n v. Norquest, 113 Nebr. 731, 204 
N. W. 798. 
98 Texas Co. v. Central Fuel Co., 194 F. 1 ; see also American Smelting & Refining Co. 
v. Bunker Hill & Sullivan Mining Co., 248 F. 172. 
99 Curtis Bros. Co. v. Catts, 72 N. J. Eq. 831, 66 A. 935. 
1 Hawaiian Pineapple Co., Ltd., v. Saito, 270 F. 749. 
