In this paper Michael Vazquez and Dustin Webster consider the practice of deliberating about ethical case studies as a means to contribute to the professional development of educators. An ongoing debate is whether or not the study of ethical theory should be included in this practice. Vazquez and Webster argue that a popular strategy, known as the Phronetic Approach, is vulnerable to what they call "epistemic blinders" that arise in the absence of the scaffolding provided by theory. They then sketch an alternative approach to case-based reasoning inspired by Barbara Herman's notion of middle theory. The middle theory approach naturally suggests a balanced method for using case studies in teacher professional development: expose educators to some theory, but only to the degree and at the level appropriate for the specific audience and in light of how frequent interactions with that audience will be.