The only animal I ever shot while laying down was a huge doe that laid down and started shewing it's cud about 40 yards from me. It was standing there and then it was gone, I scoped the area and saw it laying down, all I had was the back of its head and about a foot of neck. I pondered on whether or not to take the shot and since I had a good rest on the rails around my tree stand I decided to shoot it at the base of the skull. At the shot, the doe disappeared, when I walked down it was laying there with it's legs still folded under it. It is the only head shot I ever took and the only deer laying down I ever shot. However, I knew my gun and I had confidence in it.