Disability and 401k

My husband lost his job in feb 2018…we withdrew his 401k and had intentions of paying off a few bill and thrn rolling the rest over to an ira however, in April 2018 he had an accident and became permenany and totally disabled.  We did not roll the money over because we needed it to pay off bills.  When we filed taxes in 2019 I did not check that he was disabled because we took the money out before he became disabled. But we were able to roll it over because he became disabled.  Woukd he still have been eligible to not have to pay thr 10% penalty?  Thank you.