I really dont know. I had a returner with more return yards and about double the TD of any other, one season, and he ended up 3rd.
I think they almost have to be a returner though, to get MVP. look at Barbosa's stats. nearly all tackles, etc, were on ST too. and 219 return TD, more TD than all but 6 teams in the conference, besides the Bucs.
a lot were against easy teams in blowouts, and I kept warnin him to tone it down, with the blowout stats supposedly not really in play for MVP this season.
tough to beat, but if your guy did most fo that on ST, he definitely should have a shot at it. http://goallineblitz.com/game/player.pl?player_id=674685