Yes, actually, it has happened at SPARK once or twice.
I don't think it's resistance at a conscious level, because I've actually felt Reiki go deep in someone who said clearly that he was trying it to show that it had no effect. He said he felt nothing, but I felt it deeply. If he had stayed a little longer in the chair, he might have had to change his view. I was fine with that, am always comfortable with skeptics because I have that tendency myself.
Blessings,
Aronaya