Oddly enough my guess is from everything I have read about what was just apparently a poorly executed approach and landing, is that it would have been LESS likely to happen in IFR conditions! The crew was likely much more lax in accessing and correcting for an unstabilized approach while visually flying it than had they been flying it on instruments.
I find it weird how the "new(er) generation" flight crews have got the basic flying skills so poorly learned and/or miserably handled at times.
Surely they were in IFR conditions, just not in IMC??