I've taken out a seagull, whacked it with the right prop in the flare. I wouldn't have known it was there if the aircraft owner, sitting in the right seat, hadn't been gibbering at me not to try to dodge it.
Here's an account of a pelican taking out a 172XP.
<A HREF="http://www.ntsb.gov/aviation/mia/lnarr_94A179.htm" TARGET="_blank">http://www.ntsb.gov/aviation/mia/lnarr_94A179.htm</A>