No need for an offensive line with that!

And since you’re a lawyer, we “might” as well get to the source itself and stop talking in conversational language. The pdf is here. The download is free, and I set it to open in a new window so you don’t lose your place here. ;-)

Moving to Rules 2, Section 15, Article 10:

one player seven yards or more behind the neutral zone, no player in
position to receive a hand-to-hand snap from between the snapper’s legs,
and it is obvious that a kick may be attempted (A.R. 1-4-2-I and A.R. 9-1-
2-XXII-XXIV).
b. If Team A is in a scrimmage kick formation at the snap, any action
by Team A during the down is deemed to be from a scrimmage kick
formation.

And in the references, Approved Ruling 1, Section 4, Article 2, Statement I:

Team A, with fourth and eight, sends two substitutes numbered 21 and 33 into the game as exceptions to the mandatory numbering, and they are positioned legally on their line of scrimmage between the end players on the line of scrimmage. After the ball is snapped, a Team A player, 15 yards deep in a scrimmage kick formation, throws a legal forward pass to an eligible receiver for a 10-yard gain. RULING: Legal play (Note: The same play from a field goal formation is legal).

And Approved Ruling 9, Section 1, Article 2, Statements XXII-XXIV:

XXII. A10 is in a shotgun-type formation 7-1/2 yards behind the
snapper, who has his head down and is looking backward
through his legs. Immediately after the snap, nose guard B55
charges directly at the snapper and contacts him by pushing him
backward. RULING: Legal. The snapper is not afforded any
special protection because it was not reasonably obvious that a
kick might be attempted (Rule 2-15-10). The snapper does have
the usual protection against any personal foul for unnecessary
roughness.
XXIII. Team A is in an obvious scrimmage kick formation. Immediately
after the snap, nose guard B55 charges directly at the snapper,
contacts him, and drives him backward. The ball is snapped to an
upback three yards behind the scrimmage line or to the potential
kicker, who instead runs with or passes the ball. RULING: Foul.
The snapper may not be contacted until one second has elapsed
after the snap when Team A is in a scrimmage kick formation and
it is reasonably obvious that a kick might be attempted.
XXIV. Immediately after the snap, with Team A in an obvious scrimmage
kick formation, noseguard B71 attempts to "shoot the gap"
between the snapper and the adjacent lineman. B71’s initial legal
contact is with the lineman next to the snapper. RULING: Legal.
Incidental contact with the snapper after this initial legal contact
will not be a foul (Rule 2-15-10).

Sifting through all that, the key lies in this phrase:

…and it is obvious that a kick may be attempted.

That can be interpreted in two ways. First, “may” could imply the possibility of a kick. Second, “may” could imply the reasonable probability of a kick. The NCAA has already indicated that the second interpretation is their interpretation. (Sorry, no source. I’m not going to take the time to sift back through year-old articles.)

Here’s the reason for the interpretation: The requirement of eligible numbers on players is in place to help the officials keep track of the players during game action. The exception is granted to afford teams more flexibility in special teams personnel (specifically, to allow teams to remove dedicated offensive or defensive linemen from the field during special teams plays and also to allow the long snapper to play a non-lineman position during a game). It is a narrow exception, not a broad exception. The argument is nested in the early 1900s history of the game, but the ineligible player rule is one of the strongest elements in the game for safety reasons. (It was instituted specifically to slow down the rate at which players were getting injured and even dying in football games because the game was very nearly declared illegal by the federal government.)

No legal challenge would overcome that interpretation. If the NCAA were worried about that, they’d strengthen the ruling. But it’s a rule or reasonability, not a rule of possibility.

And it’s a lot easier to just say “might”. ;-)

In some associations, there is a rule that all kids on a team must actively play. In others, the requirement of actually playing is not necessarily there, but there is a strong encouragement to allow as many players to play as possible. So they soften the ruling a little bit from the NCAA stance to give more benefit of the doubt to teams. Basically, it’s easier to put more kids in if the refs don’t have the leverage to question a formation’s viability so long as it’s technically legitimate.

In the California association where the A-11 is being used, the rule is designed to allow linemen to come off the field. Many high schools don’t have a lot of linemen-type players to use, and some linemen are asked to play ironman due to the lack of numbers. So the softer ruling gives teams more encouragement to pull their linemen off the field on special teams plays and give them a break. In their case, it’s a fatigue and safety concern for linemen that drives the interpretation.