HeyMrMusic, it's just a gut feeling, but I don't believe the nominators would rule that both scores are unqualified, especially 'Memphis,' which got a number of rave reviews (AP, N.Y. Post, Newsday, Hollywood Reporter, John Simon, etc.).
In Tony history, they've only dropped the Score category once (1989), so it's not something they do lightly. 1989 also was a strange year in which all of the possible scores came from flop shows: 'Starmites' (60 performances); 'Welcome to the Club' (12); 'Chu Chem' (68, and 'Legs Diamond' (64).
I do agree with you, however, that the Tonys should not have nominated 'Threepenny Opera' if the nominators didn't deem it qualified enough, but there they were overruled.
Updated On: 4/18/10 at 02:26 AM