72 BULLETIN 110 6, U. S. DEPARTMENT OF AGRICULTURE 
it would call for constant supervision, but enjoined the member 
from disposing of his cranberries outside the association. 2 A simi- 
lar conclusion was reached by the Supreme Court of Oregon. 3 
INJUNCTIONS 
"An injunction is an order issued by a court of equity, requiring 
a party to do or refrain from doing certain acts." 4 Injunctions are 
usually issued to prevent a threatened injury or to restrain the doing 
of wrongful acts. Generally speaking, it appears settled that co- 
operative associations are entitled to enjoin their members from dis- 
posing of their products to third persons in violation of their con- 
tracts. Many of the cooperative statutes contain a provision entitling 
associations formed under them to the remedy of injunction against 
their members to prevent the violation by them of their contracts. 
A number of cases are cited under the preceding section which are 
directly applicable here. Other cases are here cited in which associa- 
tions enjoined their members without asking the court to decree the 
specific performance of the contract involved. 5 Independent of 
statute, the courts have held in a number of instances that cooperative 
associations were entitled to enjoin their members from disposing 
of their products outside the. association. 6 
In a few cases involving extraordinary situations, the courts have 
denied associations the remedies of specific performance and injunc- 
tion. In an Alabama case 7 the court said that the statutory pro- 
visions relative to the equitable remedies under discussion were to 
"be constructed as contemplating the use of such remedies only in 
case they shall be found consistent with commonly accepted principles 
of right and justice," and the court, therefore, completely denied the 
association the remedies in question because of a mortgage held by a 
third person on the crop. 
In a similar case arising in North Carolina 8 the court enjoined 
the member from disposing of his crop outside the association, 
subject to the right of a holder of the mortgage on the crop to demand 
and receive enough tobacco to satisfy the mortgage. 
2 Washington Cranberry Growers' Ass'n v. Moore, 117 Wash. 430, 201 P. 773. 201 P. 
811 
8 Phez Co. v. Salem Fruit Union, 103 Or. 514, 201 P. 222, 205 P. 970. 
4 22 Cyc. 740. 
6 Tobacco Growers' Co-op. Ass'n v. Jones, 185 N. C. 265, 117 S. E. 174. 33 A. L. R. 
231 ; Tobacco Growers' Co-op. Ass'n v. Spikes. 187 N. C. 367, 121 S. E. 636 ; Tobacco 
Growers' Co-op. Ass'n v. Battle, 187 N. C. 260. 121 S. E. 629 : Tobacco Growers' Co-op. 
Ass'n v Patterson, 187 N. C. 252. 121 S. E. 631 ; Potter v. Dark Tobacco Growers' Co-op. 
Ass'n, 201 Ky. 441, 257 S. W. 33 ; Burley Tobacco Growers' Co-op. Ass'n v. Devine. 217 
Ky 320, 289 S. W. 253 ; Elmore v. Maryland & Virginia Milk Producers' Ass'n, 145 Va. 
42. 134 S. E. 472 ; Wasbington Wheat Growers' Ass'n v. Leifer. 132 Wasb. 602. 232 P. 
339 ; Northwest Hay Ass'n v. Hanson et ux.. 135 Wash. 47. 236 P. 561 ; Pierce Countv 
Dairymen's Ass'n v. Templin. 124 Wash. 567. 215 P. 352 ; Washington Co-op. Egg & 
Poultry Ass'n v. Taylor, 122 Wash. 466. 210 P. 806 ; Minnesota Wbeat Growers' Co-op. 
Marketing Ass'n v. Huggins, 162 Minn. 471, 203 X. W. 420 ; Rifle Potato Growers' Co-op. 
Ass'n v. Smith, 78 Colo. 171, 240 P. 937 ; Nebraska Wheat Growers' Ass'n v. Norquest, 
113 Neb. 731, 204 N. W. 798 ; Kansas Wheat Growers' Ass'n v. Charlet, 118 Kan. 765, 
236 P. 657. 
6 Oregon Growers' Co-op. Ass'n v. Lentz. 107 Or. 561. 212 P. 811 : Pbez Co. v. Salem 
Fruit Union, 103 Or. 514. 201 P. 222, 205 P. 970, 25 A. L. R. 1090 : Wasbington Cran- 
berry Growers' Ass'n v. Moore, 117 Wasb. 430. 201 P. 773. 204 P. 811. 25 A. L. R. 1077 ; 
Grant County Board of Control v. Allohin. 152 Ky. 280. 153 S. W. 417 : Owen County 
Burley Tobacco Soc. v. Brumback, 128 Ky. 137 S. W. 710 ; Elepbant Butte Alfalfa 
Ass'n v. Rouault, N. M. , 262 P. 185 ; Manchester Dairy System, Inc., v. 
Hayward, 82 N. H. 193, 132 A. 12 ; Tobacco Growers' Co-op. Ass'n v. Joins, 185 N. C. 
265, 117 S. E. 174. 33 A. L. R. 231. 
7 Bishop v. Alabama Farm Bureau Cotton Ass'n. Ala. , 110 So. 711; see also 
Lennox v. Texas Farm Bureau Cotton Ass'n (Tex. Ciy. App.). 16 S. W. (2d) 413. 
8 Tobacco Growers' Co-op. Ass'n v. Patterson, 187 N. C. 252, 121 S. E. 631 ; see also 
Tobacco Growers' Ass'n v. L. Harvey & Son Co., 189 N. C. 494, 127 S. E. 545. 
