You can say that with him coming off a career year, and as I pointed out the same was true of Aubrey Huff 2 years ago, and isn't true anymore.
After 3 of the past 5 years, I would say that LaRoche wouldn't have been projected to have any value at all in 2015.
In any case, this is not a controversial statement to make: ML 1st basemen who are 1/9 in career years above 2.5 WAR shouldn't count on much of a bidding war if they're 35-year old free agents.
He had a terrible 2011, on which a WAR projection of 0.3 for 2015 was partly based. See the BP player profile I've attached, which does NOT factor in his 2012 standout season. 2012 will drive his 2015 projection up a tick but isn't needed to emphasize the point I'm making - that he projects to have value in 2015.
Note that he was projected to have a WAR of 1.5 in 2012 but ended up at 3.6.