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The first reason the Seventh Circuit presented for its holding in In re Sisson was that the Admiralty Extension Act (AEA) of 1948 (112) had "eliminate[d] the need and reason for the rule established by the case; for now torts are 'maritime' even when the damage occurs on land.
In their treatise on admiralty, Professors Gilmore and Black, after briefly discussing the constitutional basis of the Admiralty Extension Act in the ship-torshore collision context, (137) state the following:
In the Gutierrez case, (49) the second mentioned above, the Court extended the scope of the unseaworthiness doctrine, by way of the medium of the Admiralty Extension Act, (50) in holding in effect that Sieracki applies to injuries sustained by longshoremen when injured on the dock when engaged in unloading a vessel.
Also, since the injury here had been caused and consummated on land, absent the applicability of the Admiralty Extension Act, (31) which obviously had no application to the facts
The expanding modifications were the "aid to navigation" doctrine of The Blackheath (7) and the Admiralty Extension Act of 1948.