So this would be illegal than. I have a feeling it is even in VMC conditions when you can see the runway. 91.175 just talks about descent below MDA/DH not step down intermediate fix altitudes. So when inside the FAF is one thing but outside is quite another eh?
This is an easy one to screw up in the field.
BTW - This would really only apply to me with approaches like the BC into Santa Maria (KSMX) where it is circling only and the stepdowns are way above 3 degree's. On a normal approach it is not an issue if you are following a normal glide path in most cases.