Possibly. The term is if he "supplied more than half his own support", so if he worked and paid more than half his own bills, yes, he can file and claim himself. If he worked, but spent the money on other things, or put his earnings in a savings account, then no.
Even if the tuition was paid from a savings account, the expenses counts as part of his support. Sounds like he did not pay for it.
Besides what he earned, who paid for his support?
Link to IRS Support Worksheet
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