Relevance helps first-party characters. That's pretty undebatable. However, it's never been the end-all, be-all factor barring an exception like a retro or WTF character.
Characterizing Brawl's roster as just adding contemporary characters for their own sake seems inaccurate.
,
,
,
,
, and
being in modern games helped, but these characters are better characterized as evergreen presences in their franchises. There's a decent chance that, had none of these series received games between 2001 and 2005, they still would have been added because they're popular, made major appearances previously, and would likely appear in future scenarios. That was in contrast to
,
,
,
,
, and
, who were all rising stars that postdated Melee's roster and were partially added to modernize the roster.
Wii U/3DS
did have a very contemporary roster, but that helps further distinguish Brawl's roster as not focusing on being strictly contemporary.
,
,
,
, and
all postdate Brawl's project plan and were added at their first point of eligibility (
too, but he had a spot saved).
and
were classic characters that were reinvented in a game that postdated Brawl's project plan and they were heavily based on that appearance. Palutena was never getting in Brawl and Little Mac is so heavily defined by Punch-Out 2009 that he feels comparatively modern. Only
and
were evergreen in the sense of having a consistent, established presence in their franchises that predated 2005 and would (most likely, at the time) postdate 2012.
and
seem to confirm that you don't have to have an appearance between project plans to get into a Smash game. Yeah, they're ballot picks, but people were holding Metroid's hiatus and K. Rool's absence as an argument against their appearances. Their merits outweighed the cons of not being relevant.
Characterizing first-party selection exclusively reviewing who has appeared in games released between project plans is a bit too reductionist. Not only does it cut off characters with genuine merits like Isaac and Skull Kid, it doesn't really capture why someone like Waluigi, BWD, or Dixie Kong are likely to be added. The argument for their inclusion relative to other characters goes deeper than just being modern reps for Mario, Kirby, or Donkey Kong.
