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Hmmm... I had to research and go back to episode 21 where they first mentioned Gajeel and the Element 4. It was mentioned that the Element 4 (Juvia) were S-class in that guild. They did mention that Gajeel is a huge concern, although no mention that he was S-class.
I guess it would be possible, but not as far as I can tell from information from the anime. Either way, as Clarste mentioned, Fairy Tale might have a different standard from Phantom.
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