A federal district judge in Florida refused to order the Occupational Safety and Health Administration to withhold photos and videos of the death of a Sea World orca trainer. Judge Gregory Presnell ruled that the federal Freedom of Information Act did not allow an injunction before the agency itself had made its decision on whether to release the records.

• "Judge Denies Request To Force OSHA To Withhold Records," [2] News Media Update, Reporters Committee for Freedom of the Press, September 20, 2011, by You-Jin Han.