Technically his car is still under the old warranty so it only needs to be able to charge and drive the car.
Actually that warranty says that the replacement pack has to have
at least the same amount of capacity as his pack had
right before it failed.
And the new warranty states that the replacement is supposed to "be in a condition appropriate to the age and mileage of the vehicle
sufficient to achieve or exceed the minimum battery capacity for the remainder of the warranty period of the original battery." So replacing a battery with one with only 185 miles of range would only be acceptable if Tesla expected zero additional degradation before the end of the warranty.