It doesn't matter what kind of gun you use this can still happen. One time I shot a doe in the head to try and save meat. First shot the deer went straight down. Popped back up 2 seconds later. Second head shot, deer went straight down maybe 5 sec popped up again. Third shot, still trying to conserve meat went for the neck deer dropped, popped straight back up. This was with a 7mm mag with 150 gr ballistic tip bullets now I'm down to my last shell. Fourth shot double lung deer down for good. When I checked out the deer I shot off it's bottom jaw, blew off it's right eye along with half of the right side of it's face, grazed the spine on the back of it's neck and hit right behind the shoulder with the last shot. All of my shots were within 2-3 inches of where I was aiming. I felt sick when I seen this animal. After this deer I will never take a head shot at another deer as long as I live. I'ts just too small of a target and they are always moving their head.