I'm sure you can find a good number of monster abilities that make it harder to resurrect someone if you look.

The only example I have offhand is the Gloom Dragon in Dragon Magazine 344, which can eat the corpse of a creature 2 or more size categories smaller (you may have to shrink the corpse or enlarge yourself, especially if you're using Dragon Wild Shape as opposed to other means of acquiring dragon Su abilities), and in so doing make it so that raising the person requires that the dragon (you) be killed, followed by Wish or Miracle, and then Resurrection.