Yes. Principally, bullets can and do bounce off skulls. They'll even do very odd things like enter in the front, travel under the skin, and exit out the back. They'll get stuck in gums and teeth. Skulls are designed to protect the brain from penetrating injuries. That's their job, and they're good at it.

Second, I don't believe striking the CNS guarantees incapacitating damage. Remember this guy?



He wasn't just limping from being hit in the leg. He was shot in the brain. He was conscious, but had difficulty speaking. Still, he got up, made his way to a window, and managed to crawl out of it. If he can do that, I'm pretty sure Cletus can get another couple stabs in.

The immediate results of traumatic brain injuries are unpredictable. Peter and Joan Porco were attacked by their axe-wielding son. After the attack, Peter got up out of bed, retrieved the paper from the front yard, made himself a bowl of cereal, and started back up the stairs before he finally collapsed and died.

Third, I believe the difficulty of the shot must also factor in. The head is a small, moving target. If you miss it, your shot is wholly ineffective. In comparison, the torso is big and full of important stuff. If your counter to my "bullets bounce of skulls" objection is to dismiss such things as misses, well, you might as well ask for someone to simply shoot their attacker's trigger finger off.

Now, to be clear, if you're dumping round after round into the Center of Cletus and he's not dropping, it's time to shoot someplace else. But to me, a lot of the "just aim for the head" hyperbole sounds an awful lot like "just shoot the knife/gun out of his hand".