Absolutely.

Want me to tell you how I did it this past summer?

$2500 401K from a car dealership. Never did anything with it as I had plenty in other 401Ks. To roll it into one of the others would've been silly for two reasons a) I needed the money to help offset $8K in unexpected home and car expenses in a span of 30 days this past summer and b) I lose more than $2500 sometimes in those 401ks in a single day.

I cashed it out. Very easy. Very quick. I'd never do it on a 401K worth more than, well, $2500.

My brother used to have one of those six figure salaries in pharma (oxycotin), that went to 0 three or four years back. He was underemployed for a while and eventually had to cash out of a 401K to save the house and never paid taxes on it because of all the other losses.

It's a 10% penalty and they withhold taxes on it.