HA, BMom you do drive a hard bargain !
That culpability still remains, regardless of intent, and it is very important for whimzi to make sure, that was/is done.
There MUST be a legal complaint registered with whatever local Agency is in jurisdiction. That being the local Animal Control, or whoever is able to cause punitive legal action against the Groomer, establishing an occurrence of Disobedience. (regardless of intent).
Please excuse me for reducing this to just "something", but anything from a Letter of Reprimand, to a heavy Fine is a MUST ! And, this action should be separate from subsequent Legal recourse.
One could leave the issue of "maliciousness" to a Closing Statement.
