In 2011 People for the Ethical Treatment of Animals filed a lawsuit against ­SeaWorld alleging that five orcas were being held as slaves in violation of the Thirteenth Amendment to the Constitution; it is believed to be the first legal filing arguing that the amendment applies to non­humans. The orcas, named as plaintiffs in the case, had been caught in the wild and were being used in performances in Florida and California. “Slavery is slavery, and it does not depend on the species of the slave any more than it depends on gender, race, or religion,” PETA’s counsel said. The following year, the judge ruled that the amendment does not protect nonhumans.