There is never just cause to use pain-compliance as a behavior management tool during animal training. While some trainers and animal owners may encourage the use of pain-compliance techniques such as choke-collars and electro-shock collars, or the shoving of noses into waste, it can be demonstrated that the needs of an animal to be free from needless pain are violated by these 'techniques'. Through the use of three story examples, it is hoped that the reader may understand the point being made in this essay that pain-compliance as an animal training method is inappropriate and harmful to the animal and the relationship of the animal with the owner.