In an active noise-reducing headrest with virtual microphones, the noise attenuation achieved at the ears of the listener usually decreases significantly as the head moves away from the central seat position. This paper presents a study on designing an active headrest with robust performance against head movement. To solve this problem, a minimax optimization problem is presented to design appropriate plant models for the system. Experiments are carried out on an active headrest system with the remote microphone technique. Experimental results show that the proposed method can extend the lateral head movement range from 2 cm to about 6 cm, within which the active headrest provides noise attenuation of greater than 10 dB for both ears of the listener, and thus improve the performance robustness of the active headrest system.