- Brutal Subley
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- Noble Member
Drones, the exception being ODST because they had the shield variant which was worse.
Then Skirmishers, damn near impossible to get a headshot.
Jackals, when their shields re-spawn. Halo 3.
Berserk Brutes in H2, nothing kills them. Once had an energy sword and took 4 stabs before it fell, only to be knocked off the map by another berserker.