Actual meat shield. DnD 3.5 rule question

[Maryring]

So I'm having a bit of a conundrum. Assume that you have a bad guy and a hero. The hero is armed with various ranged attacks, so to keep the hero from shooting him, the villian is using the little mac guffin girl as a living shield against the attack of the hero.

How would you rule this effect? I don't see it just using the "shooting into melee" penalty of -4 because in this instance, the target is actively using someone else to shield himself.

[Krazddndfreek]

Use grappling rules? Maybe treat her as soft cover + firing into melee.

[The Glyphstone]

Normally, firing into melee has a -4 penalty. Living creatures grant soft cover from ranged attacks.

so, either a combination of these, or using the grappling rules (remember, the 'random chance to hit each combatant' rule still applied for ranged attacks).

[Altair_the_Vexed]

I'd use the Conan d20 rule, Human Shield.

Human Shield
You swing your distracted enemy around so as to attempt to parry another enemy’s attack with the body.
Prerequisite: Strength 13, Improved Grapple.
Circumstance: Earlier this round you have dealt damage to your opponent while grappling him, and are now being attacked by another character while still grappling the first.
Effect: If you succeed in a grapple check, you may use your grappled opponent to block an attack, just as though he were a shield. Your attacker must beat grapple check -2 to hit you, or you block the attack with the grappled foe. If you successfully parry the second opponent’s attack, full damage from that attack is dealt to the opponent you are grappling.