Our Puppy Cove geocache didn't last very long. It went missing just days after we placed it. I guess there were too many puppy's playing there. We hid it pretty close to shore, so one of the dogs must have sniffed it out. I thought about placing it inland a bit, but our antique GPSr just isn't that good under tree canopy. It's kind of embarrassing when the FTF sends you the correct coordinates.
A chair-bound person would have to get someone to make the final grab, but they can get to within 15 feet of the cache. Pretty cool.