Invincible Criminals are a myth in Grand Theft Auto IV.
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This myth, among others, is mentioned in an article from the in-game newspaper The Liberty Tree in Grand Theft Auto IV. The myth could be making a reference to Niko, Johnny and Luis, as they will always respawn at the nearest hospital if killed, or the two nightclub bouncers named Troy and Dessie, both of whom are invincible and cannot be killed by the other NPCs, possibly due to a glitch. The bouncers are featured in The Ballad of Gay Tony DLC. Troy is a bouncer at the nightclub Hercules, and Dessie works at Maisonette 9.