He earned it.
Relative to the other guys in the division perhaps, but wins over Jordan (a late replacement journeyman), Varner (whom he was actually losing to) and Fisher aren't exactly the type to stand-out in a division like LW.
Spencer Fisher was labeled as a top contender in the divison, and Franca dominated him. And Varner is a really good fighter with the potential, and I thought the fight was 1-1 going into the 3rd round.
Fisher still has not fully rebounded from the loss to Sam Stout, and at this point is teetering on verge of "Coulda'-Shoulda'-Woulda'"-dom.
To me, it's still a sign of the resurrected division's growth period that a guy with losses to most of the top fighters he's faced is its top contender (without having won a TUF title shot, that is).