Warning: This post contains SPOILERS for She-Hulk episode 1!
She-Hulk to Hulk's only solo MCU movie - even though it did not star Mark Ruffalo. Marvel has largely ignored The Incredible Hulk's impact on the shared universe or paid off any of the movie's teases.
The MCU teased a future Hulk villain in The Incredible Hulk back in 2008 with Tim Blake Nelson's Samuel Sterns. He tried to help cure Edward Norton's Bruce Banner but was then forced to help turn Emil Blonsky into Abomination. The procedure ended with a vial of Banner's blood dripping into a cut on Sterns' head, leading to his head beginning to enlarge. Marvel teased his transformation into The Leader through this moment, but he has not appeared since then. Theories have suggested he could have helped create Smart Hulk or that he could return in a future World War Hulk movie.
Thanks to She-Hulk episode 1, the MCU might have finally revealed what happened to The Leader after Incredible Hulk - and it is not good. She-Hulk's origin is similar to The Leader's in that they both have drops of Bruce's blood enter their bodies. Smart Hulk tells Jennifer that she was exposed to a lethal dose of his blood and that it is only because of a shared rare combination of genetic factors that can synthesize gamma radiation that she survived. This means that unless Samuel Sterns also had the same rare genetic factors, he would not be able to synthesize the gamma radiation from Bruce Banner's blood. While he was only exposed to four drops of it, She-Hulk episode 1 implies that this is a lethal amount, meaning The Leader likely died after The Incredible Hulk.
How Incredible Hulk's Leader Could Still Be Alive In Phase 4
Since She-Hulk does not officially confirm The Leader's fate one way or another, there is still a chance that he could be alive in Phase 4 and beyond. It is important to that Sterns was an expert when it came to studying Banner's blood. He had already duplicated the samples for more experiments, so it is possible that he also developed a small antidote. It would then be possible that Sterns was able to get a handle on being exposed to Banner's gamma-infused blood and prevented his own death. The US government or even SHIELD could have also found Sterns as the effects started to begin and helped find a way to save him.
There is also the potential for Bruce Banner's human transformation to be connected to The Leader's survival. The MCU's lack of Hulk stories has meant never revealing if Bruce and Sterns ever reconnected after The Incredible Hulk. Whether such a reveal comes in She-Hulk: Attorney At Law or World War Hulk or some other project entirely, it would be fun to learn that part of Bruce's journey to accepting being Hulk included helping save Sterns or see what he could do with his greater intelligence. That would open the door for Mark Ruffalo's Hulk and Tim Blake Nelson's Leader to interact for the first time.
New episodes of She-Hulk: Attorney At Law release on Thursdays on Disney+.