I think if UT has a winning season, Berry breaks the int return yardage record and has a few memorable plays against rivals (especially Florida and Bama), he may get an invite.
I think hell would just about have to freeze over and UT win the national title (almost impossible for any rational fan to believe) for him to have a legit shot at winning it.
Although, if Tebow tanks this year or is injured (again extremely unlikely), Berry will have ESPN on his side because of the SEC TV contract.
That said, as a UT fan I have been taught that the Heisman means practically nothing, and I don't expect a UT player to win it in my lifetime considering the school's past with the award.