It would really depend Tam. The mandatory waiting period after a discharge is past, however, lenders are going to want him to explain the reasons for the bankruptcy and to demonstrate good use of credit since then.
If he has had collections, late payments, etc since then - especially any in the last 12 months - then it might not be easy to get something right now. The credit score would not appear to be real good just yet.
That's not to say he won't be able to do it. Just that there are a lot of factors that go into a lending decision, especially after a bankruptcy.
The best bet is to speak to a lender right away and have them assess his qualificiations and provided direction on the best way to do things.