LEGAL PHASES OF COOPERATIVE ASSOCIATIONS. 29 
It is certain that a purchaser of a farm who had no notice of such 
a provision in the contract of his predecessor with a cooperative 
association would not be hound either in law or in equity." 
INTERFERENCE BY THIRD PERSONS. 
It is a general rule of law, where a stranger to a contract wrong- 
fully induces a party to a contract to commit a breach thereof or dis- 
ables such party from performing the contract, that the injured party 
to the contract has a cause of action against the wrongdoer for the 
loss suffered. 1 This principle was applied in an Oregon case 2 in 
which it appeared that an association composed of growers of logan- 
berries entered into a contract with a buyer of the berries. The asso- 
ciation had contracts with its members obligating them to deliver 
loganberries to it for delivery to the buyer. The members failed to 
deliver the berries to the association, and the buyer brought suit 
against the association and its members. The members claimed that 
they could not be sued, as the contract was with the association and 
not with them. In answer to this contention the court said : 
If the defendants be regarded as strangers to the contract of sale between 
the fruit union and plaintiff, as contended by defendants, the complaint is still 
sufficient as to the defendant growers under the rule that where a stranger 
wrongfully induces another to commit a breach of contract, or intentionally 
disables such other from discharging the obligations of his contract, the wrong- 
doer is liable in damages, or in a proper case may be enjoined from carrying 
out his wrongful purposes. 
PROMISSORY NOTES. 
It is a practice more or less followed by nonstock cooperative asso- 
ciations 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 conditions under which they are given and, of course, upon the 
law of the particular State. 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 mem- 
ber on such a note. However, this would not necessarily be true, 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 deliv- 
ered to it are accommodation notes — that is, notes executed without 
"Sjobloin v. Mark, 103 Minn. 201, 114 N. W. 746, 15 L. R. A. (N. S.) 1135. 
1 Angle v. Chicago, St. Paul Ry., 150 U. S. 1 ; Westinghouse Co. v. Diamond S. F. Co.. 
268 Fed. 121; Beckman v. Masters, 195 Mass. 205, 11 L. R. A. (N. S.) 201. 
2 Phez Co. v. Salem Fruit Union, 201 Pac. 222, 205 Pac. 970. 
