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The Admiralty Extension Act and Abandonment of the Pure Locality
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." (113) The court suggested that the "need and reason for the rule" announced in Richardson should be confined to the factual situation at issue in Richardson--that of a vessel on navigable waters causing damage to a land-based object.
(131) When Congress enacted the Admiralty Extension Act (132) in 1948 it had extended admiralty jurisdiction to damage and injury occurring on shore when caused by a vessel.
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