As I said, I don't think it correct that anyone try to place another "under the Law" so I agree that your friend is mistaking. BUT here are a few concerns I have about Ray Comfort and TWOTM (only a few as we've gone through this in the past). The reference pages are from Ray Comfort's book "The Way of the Master":
Ray Comfort teaches that “[t]hey are false converts who ‘ask Jesus into their hearts.” (14) He rightly determines a need for repentance but wrongly points to the Law of Moses in the Ten Commandments as the missing link between true and false conversion in evangelism. These are false converts because accepting the gospel “they didn’t pass through the jagged-edged teeth of the Law of God.” (276)
Romans 1 Paul, a bond-servant of Christ Jesus, called as an apostle, set apart for the gospel of God, which He promised beforehand through His prophets in the holy Scriptures, concerning His Son, who was born of a descendant of David according to the flesh, who was declared the Son of God with power by the resurrection from the dead, according to the Spirit of holiness, Jesus Christ our Lord, through whom we have received grace and apostleship to bring about the obedience of faith among all the Gentiles for His name's sake, … For I am not ashamed of the gospel, for it is the power of God for salvation to everyone who believes, to the Jew first and also to the Greek. For in it the righteousness of God is revealed from faith to faith; as it is written, "BUT THE RIGHTEOUS man SHALL LIVE BY FAITH."
OK. Look at the bolded verse (Romans 1:16). What, according to Scripture, is the power of God? The above (the NASB) says it is the gospel itself. We could even look back at what was just said and say it is the gospel in that Jesus is declared the Son of God with power by the resurrection.
How many of you here believe that the power of the gospel message is the Law?
This is what Comfort teaches of Romans 1:16 in that the power of the Law must open our eyes before the light of the gospel can be of any benefit (pg 165) and sinners must be converted by the power of god which is the Law (219). If you were not humbled by the power of the Law you are a false convert. The “power of the Law” must prepare the heart for the gospel (302).
Compare this with Paul’s words, and decide for yourselves. I believe Ray Comfort misuses Scripture and misunderstands the nature of the Law. But I also believe he has a gift for evangelism that he is just misusing at this time. God will still use the man if He desires.