Here are a few options:
RuleForModel().MustHaveAtLeastOneItemChecked();
RuleFor(model => model).MustHaveAtLeastOneItemChecked(); // not sure if this one is possible or not
ModelRule()..MustHaveAtLeastOneItemChecked();
Of course, The ModelRule method (whichever one is chosen) would need to return a different type that has more limited/different options.
I don't think it would make sense to have a lot of the standard validations such as NotEmpty() ,etc.
I really haven't thought through all of the implications of what I'm asking to be honest, and it's not a huge pain to do a workaround at the moment.