#3 Randy Orton
WWE 2K19 rating: 87
Why he could have been: The Viper is certainly a first ballot WWE Hall of Famer (not that the WWE Hall of Fame uses ballots and as long as he doesn't fall out of favor with the comp- look, you know what I meant, let's move on) and, chances are, he's probably got a few more World Championship reigns in his future. He's also only 39 years old, which isn't exactly close to retirement age in today's pro wrestling landscape.
A WWE Hall of Famer isn't a John Cena fan. More details HERE
Why he won't be: Unfortunately for the "Apex Predator", Orton's 2018-2019 hasn't exactly been eventful. While he went into WrestleMania 34 that year as United States champion, he also lost it at that same event.
After failing to regain the title afterwards, Orton underwent knee surgery, which kept him out of action for two months. At the following WrestleMania, he had a fantastic match with AJ Styles - and while it was fantastic, he didn't get the victory.
The fact of the matter is, while as great as he is, for the upcoming WWE 2K20, he just hasn't had the run to justify a 90+ rating in the game.
Of course, that doesn't mean he's not any good, kayfabe or otherwise. In fact, I expect him to be about the same rating - or close to it -he was last year. But a 90+ rating just isn't in the cards for him this October.