You better believe they are tougher to kill with a body shot. Most states restrict you to number 4 shotor smaller. And that's just too small to insure consistent penetration on body shots. I wouldn't try it with even bigger shot. Oh sure they might eventually die from such a shot. After they ran or flew 200 yards with their feathers soaking up all the blood leaving virtually no blood trail. And then crawling into the center of a downed tree top or a thicket never to be found.

It's amazing how their feathers can slow or stop shotgun pellets. I have shot them at 40 yards with no 4's and had the lower part of my pattern hit the lower feathered part of their neck and upper chest. Of course the middle and upper portions of the pattern killed them. But when cleaning them later Iwas always surprized to see how little penetration the lower neck pellets achieved. It was almost never enough to have killed them cleanly.