This comes after a penalty wasn't called when Warriors wing David Fusitu'a was tackled in the air by Bulldogs opposite Christian Crichton when contesting an attacking kick.
Unlike when tackling a defender in the air, no attempt has to be made at the ball by the defender if the attacker is in the air.
Kearney says Fusitu'a could have been seriously injured if he'd landed differently.
He says everyone saw Crichton's intention looked like he was just trying to take Fusitu'a's legs out which is dangerous.