YOU, or a tennis player in general?
Realistic....you could poop it in at 60 mph, flat, and get some in, strikepoint like a normal person's high forehand.
You can whack heck out of it, a little deadball, a little forward spin, maybe 105, and get it in once in a blue moon....
But you probably don't have the developed arms of a real wheehchair server.
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