He would not have to pay tax on any income that is a return of his contribution (what he paid in), only the earnings if it was not a qualified distribution. In addition, there is a 10% penalty for early withdrawal.
He would not have to pay the 10% additional tax on distributions that aren't more than the amount you paid for unreimbursed medical expenses during the year of the distribution, minus 7.5% of your adjusted gross income for the year of the distribution.
You can only take into account unreimbursed medical expenses that you would be able to include in figuring a deduction for medical expenses on Schedule A (Form 1040). You don't have to itemize your deductions to take advantage of this exception to the 10% additional tax.
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