Who knows, any random little thing can push it over to T.
However, the original Smash was rated E.
There was no E10+ rating when melee was released so I guess they just went on the safe side
For Brawl, I'm guessing it had part to do with Snake's realistic weapons and just the grittier art-style in general.
>That fucking down syndrome Pikachu in brawl
How the fuck did they mess up the design that bad? it looks way better in melee and smash4
Apparently there was also a trophy of Tharja in some of the ESRB leaks, which was removed from the throphy data even in the Japanese versions. That might have tipped over the T rating to E10+ as well. Anyone got that image?
But what he said isn't true. Melee was rated Teen before E10+ even existed. E10+ came into existence around 2005, 4 years after Melee's release.