I saw this at
Yahoo News.
The signal rating on a pacemaker in SR4 would likely be either 0, or a skinlinked device. Either of those is still hackable, if you're creative... routing your traffic through a Fly-Spy equipped with a skinlink would be a decent way to pull it off. You could also hack their car while they're in it, or any number of other things they keep tucked close to their body (like the ubiquitous commlink).
Even randomly firing a defibrillator is a good way to give someone a really, really bad time. I'd hate to think what someone with some understanding of heart rhythms could do.