52 BULLETIN 1106, U. S. DEPARTMENT OF AGRICULTURE. 
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- 
clation 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 ** 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 case ** decided by a Federal court in 1921, involving thé 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 personality in a case where compensation in Gamages furnishes 
a complete and satisfactory remedy. But the bill sets forth special cireum- 
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 
produce outside the association in violation of his contract. Such 
facts would constitute the “ special circumstances ” just referred to. 
Where a cooperative association is restricted by its charter or the 
statute under which it is organized to dealing with members, it would 
seem that this fact would strengthen the case of such a cooperative 
association seeking to obtain specific performance of its contract with 
a member for the delivery of produce, or for an injunction to pre- 
51 Watson v. Sutherland, 72 U. S. 74. 
52 Hawaiian Pineapple Co. v. Sait, 270 Fed. 749. 
