complex life
It's becomming apparent that there are many more scenarios for basic lifeforms than we'd ever envisioned a generation ago. But it's also become apparent that scenarios for COMPLEX life forms like highly evolved animals seem rare. The Red Dwarf scenario would require some form of shielding for the common very high energy flares which would destroy Earth type animals. Yes, less complex or very small life forms (possibly even insect level) could readily be shielded on such planets.