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If he overstayed at all, he will not be able to use the VWP again. He can try to get a B-2 visitor's visa from his US consulate. However if he overstayed by 180 days up to one year that is a three year reentry bar. an overstay of one year or more is a ten year bar. So leaving the US will trigger these, if applicable. I recommend that he schedules a consult with a competent immigration attorney to determine if any options exist and to fully analyze his case.
Answer Applies to: California