The head is a crappy target. You have to put your hits in the ocular cavity for it to be effective. Center mass body shots drop the blood pressure to the brain, which is what stops people from being a threat. Headshots are a last resort and require carefully placed shots - otherwise, you risk doing no damage. See the Miami shootout details where Maddox (sp, IIRC) was shot in the face TWICE - his CHEEKBONES stopped handgun rounds.