Not according to the FAA (I hear that CASA in Australia is updating the reg's regarding "dark night flying", so things might be different outside the US).
There is no requirement for a visible horizon when flying VFR at night. Please reference VFR Weather Minimums. Flying anywhere near those minimums is crazy as far as I care, as it's really easy to progress into IFR conditions.
Regardless of whether it's legally VFR or not, I'd feel much more comfortable being IFR rated in those conditions. I'd want the option to call in for a pop-up IFR clearance if the weather deteriorated. The limits I place personally are much more stringent than the FAA reg's, seein' as I'm a low hour "strictly for the hobby and love of flying" pilot.