Michael Hayes

I've been watching the Legends of Wrestling episodes on the network. Whenever Michael Hayes is on, the panel always jokes about him not being in the Hall of Fame. Just wondering if there is a reason why Hayes/Freebirds have not been nominated for the Hall of Fame,

I find it more odd that of all the ways you can score off Michael Hayes with cheap jokes, "Not being a Hall of Famer" is the target they go with.  
Really, he should be in either as a solo deal or with the Freebirds, and I don't know that there's any specific reason why he's not.  Maybe they're just waiting for the next Wrestlemania in the south?