He has a good amount of tissue, relatively speaking and an ugly frame, but you can't train your frame. Would be intersting to see him in "proper" shape though and how much weight he'd have to peel off. Maybe he would just lose all muscle if he continued down? There's also a lot of drug bloat, the muscle doesn't look "real."
He has issues with water retention, in addition to a bad frame and muscle insertions.
Lyle McDonald told him a long time ago that he is way too heavy for his height and structure, he should lose a significant amount of weight to stop retaining so much water and show some lines... to no avail.