LEGAL PHASES OF COOPERATIVE ASSOCIATIONS. 23 
or agreement by which a member of a cooperative association ap- 
points the association his agent for the sale and marketing of his 
products, to be valid should also contain a provision in which the 
association agrees to act as such agent and do the work in question. 
A contract should be in writing and signed by both parties. It 
should clearly and fully set forth the rights, duties, and obligations 
of each of the parties. Particular care should be taken to make, 
certain that the contract is clear upon every point involved. For 
when parties to a contract have apparently set forth in writing the 
understanding- between them with reference to the matter involved, 
it is presumed to represent the entire agreement of the parties thereto, 
and ordinarily it can not be successfully disputed by oral evidence. 
Every legitimate matter is a proper subject for contract. The law 
of contracts underlies the entire field of business and enters into every 
commercial transaction. 
CROP CONTRACTS. 
One may enter into a valid contract with another under which he 
agrees to deliver the crop to be grown upon certain land or a part 
thereof. 76 The number of cases involving crop contracts of coopera- 
tive associations which have come before appellate courts for con- 
struction are few. One of the most recent decisions 77 is that involving 
a cranberry association of the State of Washington. In this case the 
supreme court of that State said : 
The appellant makes three principal contentions: First, that the contract 
is void at common law as against public policy; second, that it is contrary 
to article 12, section 22* of the constitution of this State, which is the section 
covering the matter of monopolies and trusts, and, third, that the contract is 
void as being in contravention of the Sherman Antitrust Act, passed by the 
Federal Congress on April 2, 1890. 
The contract was upheld as against the various contentions re- 
ferred to, and an injunction issued restraining the defendant from 
disposing of his cranberries outside of the association. The contract 
involved was one of 60 similar contracts. 
An Alabama case, 78 a California one, 79 and two New York de- 
cisions 80 also support the validity of such contracts. In Iowa 81 and 
Colorado 82 the decisions indicate that liquidated damage clause 
provisions in such contracts are invalid in those States on the 
™ Butt v. Ellett, 19 Wall. 544 ; Briggs v. U. S., 143 TJ. S. 346. 
77 Washington Cranberry Growers Association v. Moore (Wash.), 201 Pac. 773, 204 
Pac. 811. 
78 Ex Parte Baldwin County Producers Corporation, 203 Ala. 345, 83 So. 69. 
79 Anaheim Citrus Fruit Ass'n. v. Yeoman, (Calif.) 197 Pac. 959. 
80 Bullville Milk Producers Ass'n. v. Armstrong, 178 N. Y. S. 612; Castorland Milk 
and Cheese Ass'n. v. Shantz, 179 N. Y. S. 131. 
81 Reeves v. Decorah Farmers Cooperative Society, 160 Iowa 194, 140 N. W. S44. 
44 L. R. A. (N. S.) 1108; Ludewese v. Farmers M. C. Co., 164 Iowa 197, 145 N. W. 475. 
82 Burns v. Wray Farmers' Grain Co., 65 Colo. 425, 176 Pac. 487. 
