I define scud-running as trying to stay below the clouds and above the ground without crashing into it.
In the report to which I linked you can see in the photos that there were no breaks in the overcast, hence no transitions from VFR to IFR and back again.
He never got to VFR on top. He flew into the solid overcast in an attempt break-out on top, became spatially disoriented, went into a dead-man's spiral and crashed.
Vertigo baby. Before he got to the crash site he was spatially disoriented. Took the road to VFR-on top too late to make it.