User blog comment:IamJakuhoRaikoben/Sorcerer Magazine, Issue 46: October 2015/@comment-4945830-20151110184114

Keyes intangibility wins him the battle arena, also necromancy is his curse so you can go ahead and say anyone he raises from the dead is valid for him to use. Juvia was a special case against him considering her own form of intangibility.