I'd bet that at 40 yds. and under it could be done; given proper shot placement between ear hole and eye socket. I used to help a friend thin out woodchucks on a small field and out to at least 50 yards we did head shots with 22 LR and those usually were DRT. That was when I learned that a 22 LR has more killing power than I had thought. Based on viewing the results I was surprised by the penetration & destruction displayed even through bone at those ranges. Put one of those in the ear hole of a stationary deer and I doubt it will go far if it goes anywhere at all. Having said all that I'd still step up to at least my 22 Hornet for that scenario or else my buddies would be accusing me of "stunt shooting".
