Bob ... no offense meant, but have you tested that ?
All of the nursery sites say that heucheras are deer resistant. My deer can't read and they ate my first ones to the crown the first night I had them out in front of the house. When the doe got into the house pad garden last fall, she ate every one of my heucheras to the crown, too.
http://garden.org/thread/view_...
The doe even chomped my star magnolia ...
I'd love to plant painted ferns out in front of the house. They have been on my wish list for years. I also have the perfect spot for a Godzilla fern out in deer territory under my maple tree.