He definitely needs to fully heal before he's judged, but his throwing motion does seem a little off.
It's looked like that since he changed his motion when he got hurt the last time. Once he worked through the kinks he was actually more accurate. Everyone is going to have bad throws on occasion.
It's been like that for 3 years. If he could make the normal, easy toss to first as well as he throws on the run, he'd win a GG every year
If he can stay on the field, he'll win it most years.