While I agree, there is some basis to stand on. BC lost 7 games last year. You are 100% correct that if ND wasn't a NC contender this year he wouldn't be in the mix. However the Heisman trophy is:
The Heisman Memorial Trophy annually recognizes the outstanding college football player whose performance best exhibits the pursuit of excellence with integrity. Winners epitomize great ability combined with diligence, perseverance, and hard work.