Originally posted by The Mexican
Where was he shown to be below top tier?
As estacado pointed out, in comics, it's guilty till proven innocent. I could just as easily say "What did bystander 5543 do to show he was below the top tier?"
Further more; I didn't say be was below top tier, I said he wasn't above top tier.
Finally, all he had was a bit of strength and durability - clearly tailor made for a battle with the Hulk. Unluckily for Banner, the JLA almost ALL have a wee bit more versatility than 'punch, punch, kick, throw.'