LEGAL PHASES OF COOPERATIVE ASSOCIATIONS. 51 
In a Pennsylvania case 50 a baseball player of unusual and extraor- 
dinary ability and note who had contracted to play with a cer- 
tain team, and not to play with any other, was enjoined from playing 
with any team other than the one with whom he was under contract. 
There have been many cases analogous in principle with the one just 
referred to in which similar conclusions were reached. 51 Emphasis 
in these cases is laid on the fact that the services are extraordinary 
and unique and that no certain pecuniary standard exists for the 
measurement of the damages. 
In the Washington case in which the cranberry association en- 
joined the member from disposing of his cranberries to outside 
parties the court stated that it would not be proper to decree specific 
performance of the contract, as it would involve continuous super- 
visory duties by the court. However, it granted an injunction which 
prevented the member from selling his cranberries outside of the 
association and which operated to compel their delivery to the asso- 
ciation if marketed at all, thus accomplishing indirectly through the 
remedy of injunction what the court declared could not be done 
through a decree for specific performance. 
In general, an injunction can not be obtained where the remedy at 
law is adequate, which in most instances means that if damages will 
compensate the party seeking the injunction his right thereto will 
be denied. In a case 52 decided by the Supreme Court of the United 
States the court said: 
It is contended that the injunction should have been refused because there 
was a complete remedy at law. If the remedy at law is sufficient, equity can 
not give relief, but it is not enough that there is a remedy at law ; it must be 
plain and adequate, or in other words, as practical and efficient to the ends 
of justice and its prompt administration as the remedy in equity. 
In a ease 53 decided hj a Federal court in 1921, involving the right 
to an injunction to restrain the sale of a crop of pineapples and to 
obtain a decree for specific performance thereof, appears the follow- 
ing: 
It is true that equity will not decree the specific performance of a contract 
which relates to personalty in a case where compensation in damages furnishes 
a complete and satisfactory remedy. But the bill sets forth special circum- 
stances, the allegations of which it is unnecessary here to repeat, that show 
that there was no adequate remedy at law. 
Instances can easily be conceived of in which produce contracted 
for by a cooperative association would be vital and necessary to the 
successful operation of the association. Under such circumstances it 
is believed that a court would enjoin a member from disposing of his 
s° Philadelphia Ball Club v. Lajoie, 202 Pa. St. 210, 51 Atl. 97S', 59 L, R. A. 227. 
51 14 R. C. L. 3S6. 
52 Watson v. Sutherland, 72 U. S. 71. 
53 Hawaiian Pineapple Co. v. Sait, 270 Fed. 749. 
