Not really. Theres just no ration reason for him to be in from any perspective. Other characters are more popular and requested by fans. Other characters will make more money for both Nintendo and Capcom. Because Viewtiful Joe's series has been discontinued, such couldn't even be used for advertising. Theres simply no logical reason that could possibly get him into Brawl.
Zevox
When has logic, and/or popularity been a thing that dictates 100% of what goes in the world of Smash?
Was there any real logic that dictated that Roy got in, as opposed to another, much more popular FE Lead like Sigurd, Celis or Leif? Nope, not really, Roy only got in the game predominantly to advertise for the (at the time) upcoming GBA game starring him. People ended up not liking it much, any way, but that's ancient history now.
Was there any real logic behind G&W, a character that 90% of modern gamers probably had no idea what he was about and where he came from, at the time? Not really, he was just put in as a means to pay tribute to another, much more obscure time in Nintendo's life as a game manufacturer. This similar argument carries over for the Ice Climbers, as well.
Hell, even now, we see some things that just defy logic, or what popularity would have lead some to believe. Deoxys is a Pokeball Pokemon, instead of the playable that a lot wanted. Little Mac got passed over and made into an AT, as well.
And why could this happen? Because, in the end, Sakurai already admitted that he's not committed to providing fan service in all respects; just because some thing is grossly popular, in no way necessarily guarantees that character will be playable. He's already stated as such that "only having popular characters is boring", to put it bluntly.
So, while I don't think Joe has much of a chance either, he still does have A chance, and that's enough for me. If Smash could be conceived as a way to jump start his career, that could be all the more reason to put him in.
Oh...and any notice that Olimar's Final Smash involves him coming down and crashing back down to Earth, as well as the "dangerous beasts"? Hmmm...