Flying for 3 hours without checking the weather at all and even getting into that situation. I'm kinda new here. I see that has already been talked about. I just responded to the original post without reading all the responses first.
While it's wise to do so, I'm not aware of a requirement to check weather en route. And unless the avionics had a known deficiency when he took off, I think they would be hard pressed to call it an emergency of the pilot's own making, given that lost comm is so rare.