This story was told to me as true: A guy I went to high school with was out hunting squirrels in October with a .22 rimfire. Seeing a deer, he killed it with a head shot from the .22. As this was during Illinois archery season, and as this guy had an archery tag, he shoved an arrow into the bullet hole, tagged the deer and took it to the check station and got it checked.(This was back when you actually had to haul your dead deer to the check-station.)
It sounds plausible, but I have to wonder why the DNR guys at the check station weren't a bit suspicious of a deer head-shot with an arrow. Not being A bow hunter myself, I'd think it would be difficult to kill a deer by shooting it in the head with an arrow.
