With that much determination I recommend keeping your garbage out of reach too. If I turn my back even for a second to get a new bag my rabbits will be in it looking for anything out of the norm. Bad rabbits!
Jay and I are housemates with a 15 lb motherf*cker whose favorite past time is knocking over the kitchen trashcan, both to look for noms and just to be obnoxious and prove that he's gonna do whatever the hell he wants to.
If the trash can is empty, he knocks it over. If it's full, he knocks it over. As soon as he learned he could do it for the first time, he started knocking it over at least half a dozen times a day. I tried numerous preventative measures without success - the only one that worked was putting up a baby gate, which was obnoxious because then we had to step over it all the time to get anything from the kitchen.
A few days ago, I'd finally had enough - for the second time in 10 minutes, I was cleaning leftover spaghetti (with sauce) and the previous night's glider leftovers (messy/juicy diced fruits and veggies) off of the kitchen floor. I went to Home depot and grabbed some wood from the 70% off "defective" lumber pile, came home, broke out my mini circular saw and a box of nails and reinforced our kitchen trashcan by ghetto-rigging a stable base to place it in:
He's been pouting, staking it out for hours at a time and giving me dirty looks ever since but the trashcan seems to be thoroughly immovable as far as he's concerned. We're overjoyed and, I must admit, Jay and I have both been rubbing it in his face at every opportunity.
We also have an identical 13 gallon trashcan in our bedroom, which I haven't gotten around to a**hole-proofing yet. Yesterday, Roo was on the bed and I said something or other that he deemed offensive enough to make a statement about (I might've been mocking him about how he couldn't topple the kitchen trash any more), so he got up and went right over to the virtually empty trash can in the bedroom, knocked it over to make a point and then walked off.
Don't get me wrong, we love Roo to pieces and wouldn't trade him for anything in the world... but he really, truly is a motherf*cker (and extremely proud of it, to boot), as is evidenced by the lengths I had to go to in order to defend our trashcan.