There are always spells that couldn't be resisted by SC.
'Life for life' or 'drain life' for example. They are undead and you can't drain life? Cast 'dust to dust', 'whither bones' or 'maggots'. They are lifeless? Then cast 'shutter'.
And don't forget you can always lock them in inferno or cocytos. There are also some advanced tactics.
Edit: ninja'd.
