It is not an easy task to prove a claim of inadequate training against a municipality. When a plaintiff sues for the actions of an officer, he/she must demonstrate two elements: a municipal employee committed a constitutional violation; and a municipal policy or custom was the moving force behind the constitutional deprivation. Many plaintiffs fail when attempting to prove the required “deliberate indifference.” Proving deliberate indifference is difficult because the plaintiff must prove the need for different training is so obvious that policymakers deliberately turned a blind eye to the problem. The courts have signaled a need for more realistic, hands-on firearms training. The courts have suggested training methods such as live shoot/don’t shoot courses using role-playing actors as perpetrators. Many believe this is not only impractical but also potentially dangerous. Courts also have expressed the need for night training. Courts seem to be looking for specialized firearms training based on individual situations. They are reluctant to hand down an all-inclusive outline for firearms training because the circumstances surrounding each incident are unique and deserve to be addressed on a case-by-case basis. One step in creating court defensible firearms training programs is to scan the courts’ rulings. Incorporating what the courts’ view as most beneficial and efficient remains an ongoing challenge for many police departments.