ABSTRACTCollective action frames are a key strategy of human rights activists and educators, and central to this strategy is the ability to connect frames to a population's extant beliefs. But two dilemmas plague framing efforts directed at state agents such as police officers, who are seen as potential violators of rights. First, these actors may be less likely than members of the general public to share the beliefs in terms of which human rights workers frame rights; and second, frames by their very nature simplify reality, and fail to take into account factors that constrain state agents' actions. This article explores these issues through a case study of human rights education involving police officers in India. Educators may be able to mitigate such obstacles by basing their framing efforts on research on the specific populations with which they are working, and using frames as only one part of an approach that takes into account the limited ability of frames to encompass all aspects of the situations in which violations occur.