I don't know for sure, but I think imitating a player's likeness without their consent has become a little more serious since the 90's. A few years ago I think there was a lawsuit brought about in part by Ed O'Bannon, who felt his likeness was being used by college basketball games without his consent, even though it was a nameless guy who happened to have all his attributes on the '95 UCLA squad. If nothing else, I always figured such a lawsuit scared developers from making any generics even vaguely resemble real players.
http://www.nytimes.com/2010/03/11/sp...1colleges.html