The notion that a CCW permit holder firing in the theater might have caused collateral injuries or death is an interesting one to ponder...could happen even with a police officer. Interestingly, John Lott said on last night's Mark Levin show that he can't find a case where a CCW involved in a shooting involved a bystander.
It is likely that active training scenario's for CCW holders, if not already, will be tailored to include low light situations against "hardened targets" wearing apparent body armor. It is still not clear that what this nut had was actual body armor, even though it looked like it.
Always amazing the mindset that liberals have taken on as doctrine. Non law enforcement people with guns are de facto dangerous.