## Facts

- Four men sailed two 18-foot Hobie Cat sailboats across Pamlico Sound to Silver Lake at Ocracoke, North Carolina, a tidal, navigable body of water.
- While beaching a sailboat, its mast contacted an energized, uninsulated overhead power line carrying about 7,200 volts, owned and maintained by Tideland Electric Membership Corporation.
- One sailor survived; three were electrocuted and died.
- At the moment of contact, the sailboat was seaward of the mean high-water mark (within tidal waters adjacent to shore).
- The decedents’ estate representatives sued Tideland and the sailboat-related manufacturers/sellers (Coleman Company, Inc. and Coast Catamaran Corporation), alleging negligence and products-liability theories.
- Plaintiffs invoked federal admiralty jurisdiction; defendants moved to dismiss for lack of subject-matter jurisdiction.
- The district court denied dismissal, and defendants took interlocutory appeals limited to the admiralty-jurisdiction ruling.

## Issues

1. For a tort in tidal navigable waters, does the admiralty locality requirement extend to the mean high-water mark rather than the waterline at the time of the incident?
2. Does the “extension of land” doctrine bar admiralty jurisdiction when the injury-causing instrumentality is an overhead power line associated with land-based structures?
3. Does recreational sailing and the alleged negligence/defects relating to a sailboat and a hazard over navigable waters satisfy the “significant relationship to traditional maritime activity” requirement?

## Decision

- The Fourth Circuit affirmed the denial of the motions to dismiss and held admiralty jurisdiction existed.
- Admiralty locality in tidal waters extends to all areas within the mean high-water mark, regardless of the tide level at the time of the accident.
- The extension-of-land doctrine did not apply because the injury-causing instrumentality was over navigable waters and the accident occurred in the maritime setting.
- The incident satisfied the maritime nexus requirement because navigation of a vessel on navigable waters, including recreational sailing, is traditional maritime activity, and the alleged conduct concerned hazards and vessel operation in that environment.

## Legal Principles

- Admiralty tort jurisdiction requires (1) a wrong occurring on or over navigable waters (locality) and (2) a significant relationship to traditional maritime activity (nexus).
- In tidal navigable waters, the locality boundary for admiralty jurisdiction reaches the mean high-water mark, avoiding jurisdictional outcomes that turn on changing tides.
- The extension-of-land doctrine generally covers injuries occurring on land-based projections into water (e.g., piers/docks) and does not categorically convert an overhead hazard over navigable waters into “land” for admiralty purposes.
- Recreational vessel navigation can satisfy the maritime nexus requirement; alleged failures in vessel design/warnings and placement/maintenance of hazards over navigable waters may implicate maritime safety.

## Conclusion

The court held federal admiralty jurisdiction covered the electrocution accident because it occurred within the tidal zone up to the mean high-water mark, was not excluded by the extension-of-land doctrine, and bore a significant relationship to traditional maritime activity through vessel navigation and maritime-safety-related allegations.


Hassinger v. Tideland Elec. Membership Corp., 781 F.2d 1022 (4th Cir. 1986)