My implementation of the patch may not be the most effective way to accomplish this, but the bug prevents a true Locale specific implementation of Forms with Dates.
From the Struts Validation Documentation (which holds true on the server side validation):
"If no pattern is specified the default short date format is assumed."
The real patch is when looping over form fields from validation.xml. I check if it is a type "date" then keep track of whether or not a var named "datePattern" exists. If not, I add datePattern based on the Local passed in.
Please let me know if I can help. This is a really important feature for my application.