In determining police departmental liability in officers' use of their firearms, the courts have set only broad guidelines for such training, leaving it to individual departments to develop firearms training programs best suited to their needs. The courts have indicated that the liability issue is based in a determination of the "adequacy of the training program in relation to the tasks the particular officers must perform" (U.S. Supreme Court in City of Canton v. Harris). In firearms use and training, the tasks relate to proficiency and judgement. Proficiency relates to an officer's skill in using a firearm, that is, handling it safely and firing it accurately. This training should be tailored to the weapon's characteristics and potential and to the typical circumstances in which police officers will likely use it. Of equal, if not greater, importance to training is the cultivation of an officer's judgement regarding when it is appropriate to use a firearm. Training should incorporate legal and policy guidelines on the use of force, as well as practical instruction on how to apply them. Any training deficiency that incurs liability must evidence a "deliberate indifference" to the safety of the community and must cause a constitutional violation before a plaintiff can prevail. Training programs that focus on proficiency and judgement in the use of firearms will meet this test. 38 footnotes