It depends on how much he earned. If he earned more than the standard deduction of $14,600, then yes, he will need to file a return as he would have taxable income. Also, if he is paid as an independent contractor and makes more than $400 then he would need to file a return as he could have Self-Employment Tax liability.
Being a student or working for a small business does not change whether or not he has to file. It is based on what he earns.
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