Many MS65 Morgans aren't as nice as my 1902-O, which doesn't imply that they're all overgraded. I think the TPGs are doing a pretty good job with grading and attributing Morgans (PL, DMPL, VAM variety, star, etc...). Considering how many Morgan dollars were graded in the past 20-30 years, there'll inevitably be a coin or two which they "got wrong"...