A SeaWorld trainer drowned in 2010 when a killer whale pulled her beneath the water during a live show, marking the third fatal attack during a performance and sparking an investigation into employment risks at the Florida theme park.

Federal occupational safety regulators faulted SeaWorld of Florida LLC for exposing its trainers to recognized hazards, and the case made its way to the U.S. Court of Appeals for the D.C. Circuit. The court in 2014, ruling for the Occupational Safety and Health Administration, said SeaWorld failed to take steps to protect employees from the hazards posed by close contact between trainers and killer whales. The appeals panel was sharply divided.