this motion that no warning was given. The question before the Court is whether on this evidence, a finding of vessel negligence may be sustained. Since the 1972 amendment of Section 5(b) of the Longshoremen’s and Harbor Workers’ Compensation Act, liability may no longer be premised on unseaworthy conditions but requires proof of negligence by the vessel. 33 U.S.C. § 905(b). In determining whether negligence has been established, the federal courts look to uniform land-based principles. See, e. g., Hurst v. Triad Shipping Co., 554 F.2d 1237 (3rd Cir. 1977). The courts have been vigilant in guarding against any expansion of vessel liability which might restore the situation the 1972 amendment was intended to cure. See, e. g., Wescott v. Impresas Armadoras, 564 F.2d 875 (9th Cir. 1977) (<HOLDING>). It is important at the outset to define the
holding a directed verdict motion stating specific grounds is a prerequisite for a subsequent motion for judgment notwithstanding the verdict holding defendants failure to file motion for judgment notwithstanding verdict did not prevent district court from granting motion for directed verdict for which court reserved decision holding that a posttrial motion is not required after a grant of a directed verdict holding that the trial court erred in granting the school boards posttrial motion for directed verdict because although the school board timely moved for a directed verdict during trial it did not serve its motion for directed verdict until the eleventh day after the verdict holding that the trial court erred in refusing to grant the vessels motion for directed verdict and judgment n o v where a longshoreman was injured while knowingly engaged in loading a vessel in a dangerous manner