NBA ShootOut and its successor series NBA 0x (often tagged with "The Life" or "The Inside" and are on PS3/PS2/PSP only) have been produced by Sony since the mid-90s.
In 2003, MJ either retires after the first or the second year of the franchise. If he doesn't retire, he drops from like 88 overall rating down to the upper 60s, his stats drop off the edge and he's never on a team.
Like most 40+ year old NBA players. They wouldn't write extra development code in franchise specifically for him.