What is the statute of limitations for personal injury claims at sea?

By the beginning of the 1980s, federal law expressly provided a three-year limitations period for personal injuries at sea, see 46 U.S.C.App. 688, and a two-year limitations period for death on the high seas, see former 46 U.S.C. 763 (since repealed). See Usher, 27 F.3d at 371. But "[o]ther claims ... were [still] governed by ... laches" until 1980, when 46 U.S.C.App. 763a imposed a three-year statute of limitations on maritime tort claims in general. Id. Because Dickey was decided before 763a, that case was governed by the historical rule in admiralty that "the delay which will defeat ... a suit must in every case depend on the particular equitable circumstances of that case." The Key City, 81 U.S. at 660; see also Czaplicki v. The Hoegh Silvercloud, 351 U.S. 525, 533, 76 S.Ct. 946, 951, 100 L.Ed. 1387 (1956). Dickey is therefore not dispositive.