41 minutes ago, Iuchi Toshimo said:My speculation assumes all abilities can be used from home and while bowed (see Shinjo Outrider and Border Rider) and that speculation currently extends to Phoenix personalities that require control of certain rings.
Given that we've now seen cards that specify the personality has to be attacking, or in a conflict, to use their ability, and cards that do not, I think we can safely conclude that the two Phoenix shugenja we've seen so far can be used in a conflict while not actually in the conflict.