Pope and Young FAIR CHASE rule #3:
No animal taken behind he confines of a fence shall be considered fair chase.

Deer behind fences are captive.They cannot escape. They are not free ranging. And in my state hunting behind a fence is illegal.

Anyone who is a millionaire can buy a thousand acres or more and fence it in. Then they can put out tons of just the right minerals and plant just the right crops and feed the deer high protien diets for the biggest bodies and the best racks. At this point it becomes a zoo. Then they can charge big bucks for people to hunt there. Unfortunately this has become big business in Texas and some other states.