Crossword Genius

In a nutshell, one who is unlikely to change (4,4)

Ross

I believe the answer is:

hard case

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(Other definitions for hard case that I've seen before include "challenge to legal team?" , "Tough person to deal with" , "Tough guy" , "Brief problem, perhaps" , "Intractable person" .)

I've seen this clue in the Evening Standard.
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