Back when the Seecamp was a .25 ACP, a friend who needed a deep carry pistol got one. He had a ND while standing next to his bed. This has been 25 or more years ago, and I don't recall the exact details of HOW the ND happened. In any event, the FMJ bullet penetrated his pillow and was laying on top of the sheet.

He sold it the next day and got a S&W Model 19 with 2 1/2 inch barrel.