One of the most legendary minds in NBA history, Phil Jackson, famously publicized his theoretical rule that teams must win 40 games before they lose 20 to be considered true title contenders. Since the three-point line was added in 1979, there have been 46 champions — and only four have failed to hit this mark.

Hitting at over a 91% success rate and brought to light by a coaching icon who helmed 11 championships between the Bulls and Lakers, this rule isn’t an exact science, but it’s a pretty reliable compass for separating contenders from pretenders.
Applying that rule to the current season, we already have two clear teams who have punched their ticket: the Pistons at 40-13 and the Thunder at 42-14. The Spurs look well on their way at 38-16 heading into the break. Then there are the Celtics, sitting at 35-19 and still very much alive — though they’ll need to run the table in their next five games to reach the magic 40-win threshold before 20 losses.
It won’t be easy. Boston heads straight into a brutal four-game road trip against the Warriors, Lakers, Suns, and Nuggets, followed by a home date with the Nets. But even if they fall just short of the 40-20 mark, all hope is far from lost. History shows there are always exceptions — and the Celtics are perfectly positioned to become the latest, and most dominant, outlier yet.
The four teams that previously broke the mold all shared one critical trait: unique, season-altering circumstances that flipped the script at exactly the right moment.
The 1994-95 Rockets were defending champions who pulled off a blockbuster mid-season trade for Clyde Drexler, instantly supercharging their roster for the stretch run and eventual title.
The 2003-04 Pistons started strong at 33-16, hit a wall, then transformed themselves by acquiring Rasheed Wallace — a veteran infusion that turned a good team into champions.
The 2005-06 Heat began 11-10, lost head coach Stan Van Gundy, and watched Pat Riley step in as player-coach. Riley’s leadership sparked a late surge straight to the championship.
And the 2020-21 Bucks navigated the bizarre, shortened COVID season played in near-empty arenas across strange months — an unprecedented environment that ultimately fueled their breakthrough.
What do all these champions have in common? A pivotal mid-season catalyst that changed everything.
Now look at the Celtics. Their catalyst is already written in the stars: the imminent return of perennial MVP candidate and All-NBA First Team lock Jayson Tatum.
There’s no guarantee on the exact timeline, but when Tatum steps back on the floor, he won’t just be “returning” — he’ll be the ultimate in-season game-changer. Whether he immediately looks like his MVP-caliber self or eases in, the impact mirrors (and likely exceeds) the boosts delivered by Drexler in ’95, Wallace in ’04, or Riley’s coaching takeover in ’06. Add in a roster that was already built to win now, and Boston suddenly possesses the exact kind of unique, transformative circumstance that has defined every previous exception to Phil Jackson’s rule.
So while the 40-20 conversation will dominate the next couple of weeks, remember this: exceptions aren’t random — they’re destiny in disguise. The Celtics aren’t just trying to scrape by the mark. They’re built to transcend it.
Absolute dynasty incoming.