I assume that your friend was undocumented in this situation.  If that is the case, he can be deported even with no criminal record.  Just being in the country without documents is enough to get deported.Generally, the ten year bar on returning to the U.S. has to do with unlawful presence. If someone is unlawfully present in the U.S. for over a year, that person must wait ten years before applying for a visa to return.Without any further specific facts about this situation, I would say that your friend will need to wait the ten years before trying to come back.