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Because the team that owns the stadium the game is scheduled to be held in has never won its conference championship. There's no rule against it, tho. In 2016, the Super Bowl will be held in San Francisco at the stadium they are about to start building. If the 49ers are NFC conference champions that year - possible; the 49ers are a good team - they will play the Super Bowl in their own stadium. (The same thing can be said about next year if the Arizona Cardinals play their way into the game, which will be held in Phoenix, or in 2017, if the Houston Texans play their way into the game that will be held in Houston.)
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