Due to statistical analysis, the issue of random sampling is pertinent to any quantitative study. Unlike quantitative study, the elimination of inferential statistical analysis, allows qualitative researchers to be more creative in dealing with sampling issue. Since results from qualitative study cannot be generalized to the bigger population, qualitative researchers do not have to endure the strenuous randomization process of sampling procedure. However, qualitative researchers should not take sampling procedures too lightly, and if they do, it will affect the richness and the appropriateness of the data. The chances are, the data will not answer their research questions and this can frustrate the researchers when making meanings to the data. This paper will examine the available methods in sampling participants for qualitative study. Specifically, the paper will discuss the sampling frame suitable for case study, such as single-case (holistic and embedded), multi-case, and a snowball or network sampling procedure. Discussion will also involve challenges anticipated for each procedure.