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The Courts of Appeals sitting in admiralty overwhelmingly have adopted concepts of products liability, based both on negligence, Sieracki v. Seas Shipping Co., 149 F.2d 98, 99-100 (CA3 1945), aff'd on other grounds, 328 U. S. 328 U.S. 85 (1946), and on strict liability, Pan-Alaska Fisheries, Inc. v. Marine Constr. & Design Co., 565 F.2d 1129, 1135 (CA9 1977) (adopting Restatement (Second) of Torts § 402A (1965)). Indeed, the Court of Appeals for the Third Circuit previously had stated that the question whether principles of strict products liability are part of maritime law 'is no longer seriously contested.' Ocean Barge Transport Co. v. Hess Oil Virgin Islands Corp., 726 F.2d 121, 123 (1984) (citing cases). 


The Supreme Court recognizes products liability, including strict liability, as part of the general maritime law. The Court's precedents relating to injuries of maritime workers long have pointed in that direction. See Seas Shipping Co. v. Sieracki, 328 U. S. 85, 328 U. S. 94 (1946) (strict liability for unseaworthiness); Italia Societa per Azioni di Navigazione v. Oregon Stevedoring Co., 376 U. S. 315, 376 U. S. 322 (1964) (strict liability for breach of implied warranty of ...

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