In Foremost Ins. Co. v. Richardson 1 the Supreme Court of the United States held that a complaint alleging a collision between two pleasure vessels on navigable waters properly states a claim within the admiralty jurisdiction of the American Federal courts.2 The court acknowledged that under its earlier decision in Executive Jet Aviation Inc. v. City of Cleveland 3 the traditional “locality” test was no longer sufficient to determine whether Federal admiralty jurisdiction was proper. In rejecting the strict application of the “locality” test, the court essentially fashioned a test for admiralty jurisdiction which requires not only occurrence of the tort on navigable waters but also a sufficient relationship between the tort and traditional maritime activity.4 The Richardson Court then attempted to define the scope of traditional maritime activity.

Clyde Richardson was fatally injured when his pleasure boat collided with another vessel on the Amite River in Louisiana.5 One boat was pulling a water skier at the time.6 The second vessel was a “bass boat” used exclusively for pleasure fishing.7 At the time of the accident, the two crafts were headed in opposite directions.8 Apparently the “bass boat” was traveling north and made a left turn into the path of the southbound ski boat.9 Richardson’s wife and children brought the action in the U.S. District Court for the Middle District of Louisiana, alleging that defendant