According to the accident reports, it was primarily pilot error that caused the crash. The pilot had overestimated his abilities but wasnt qualified to fly under such conditions (nighttime during a snow storm). It required a pilot who was properly trained to fly by his instruments. 9 months earlier the pilot was tested for his certification for that particular thing, but he flunked.
It was VFR, a 5000 ft ceiling (no visibility given in the report) in light snow. Yes, it was at night, but if he couldn't manage VFR @ night, he wasn't competent anyway. Night VFR flight doesn't require an instrument rated pilot, but vertigo is a real hazard and having some experience using the instrument in primary scan at night is a good practice. The fact he crashed so soon after takeoff indicates that he failed to stay oriented and was that condition was likely made worse by the gusty winds.
Now, this was in Instrument conditions with a qualified pilot during the day trying to get to Fargo.
Mishap report