92 BULLETIN 110 6, U. S. DEPARTMENT OF AGRICULTURE 
closing hours for other establishments were not fixed. 89 A statute of 
Mississippi which forbade corporations from operating both cotton- 
oil mills and cotton-oil gins, but which permitted the operation of 
either by any corporation, was held constitutional. 90 A statute of 
Kansas which distinguished between farmers' mutual insurance com- 
panies and those operated on a commercial basis was also upheld. 91 
The right of employees to form labor unions to bargain collectively 
and to follow up their demands by orderly strikes is established. 92 
PROMISSORY NOTES 
It is a practice more or less followed by cooperative associations 
to receive the notes of their members for specified amounts for the 
purpose of using them as collateral for loans that may be necessary 
in the conduct of the association's business and for other purposes. 
The exact character of such notes depends upon the terms and con- 
ditions under which they are given and upon the law of the par- 
ticular State. 93 For instance, if at a meeting of an association a 
majority adopts a resolution specifying that " each stockholder 
should pledge himself for the sum of $350 to indemnify and save 
the directors harmless " from any Joss for becoming personally 
responsible to the creditors of the association, and only a part of 
the stockholders execute such notes, the association can not success- 
fully sue the stockholders that do not execute such notes, because 
" the stockholders present at the stockholders' meeting could not 
bind those not present who failed or refused to comply with the 
terms of the resolution." When anyone failed or refused to sign, 
no obligation to pay was imposed on those who did sign, 94 but if all 
the members enter into an agreement to protect the association 
the obligation is otherwise. 95 
The by-laws of an association usually set forth the agreement 
between the association and the members relative to the notes, and 
this agreement would probably in all cases determine the character 
of the notes as between the association and a member, and whether 
the association could successfully sue a member on such a note. This 
would not necessarily be true, however, as will be shown later, as 
between a third person who had received the note of a member from 
the association. 
If the notes executed by the members of an association and de- 
livered to it are accommodation notes — that is, notes executed with- 
out consideration and for the purpose of enabling the association 
to borrow money or obtain credit thereon — then it is settled that 
the association could not successfully sue a member on such a note. 
The maker of an accommodation note is known as the accommoda- 
tion maker. He receives nothing for executing the note and signs 
it to enable the one in whose favor it is drawn to obtain money or 
credit from some third party. The fact that a note or other negoti- 
89 Petit v. Minnesota, 177 U. S. 164, 20 S. Ct. 666. 
90 Crescent Cotton Oil Co. v. State of Mississippi, 257 U. S. 129, 42 S. Ct. 42. 
91 German Alliance Insurance Co. v. Lewis, Superintendent of Insurance of the State of 
Kansas, 233 U. S. 389. 
92 American Steel Foundries v. Tri-City Central Trades Council et al., 257 TJ. S. 184, 
209, 42 S. Ct. 72 ; Truax et al. v. Corrigan et al., 257 U. S. 312, 357. 42 S. Ct. 124. 
93 Farmers' Equity Co-op. Ass'n v. Tice, 122 Kan. 127, 251 P. 421 ; Elmore v. Maryland 
& Virginia Milk Producers' Ass'n, Inc., 145 Va. 42, 132 S. E. 521. 
04 Farmers' Co-op. Union et al. v. Alderman et al., Kans. , 267 P. 1110. 
96 Farmers' Equity Co-op. Ass'n v. Tice, 122 Kan. 127, 251 P. 421. 
