There are cases where it is considered justified, although it wouldn't apply to train heists, at least in California [1]. Some have claimed the justification to shoot someone for stealing at night in Texas has a biblical origin [2].

[1] https://reason.com/volokh/2020/06/02/are-people-allowed-to-u... [2] https://www.biblegateway.com/passage/?search=Exodus+22%3A2-3...