In 1982 Sowell suffered kidney failure that he believed was induced by glaucoma drugs. He had a kidney transplant that required him to take antirejection drugs that render him nauseous. He found that marijuana helped control his glaucoma and nausea. Sowell tried but failed to obtain marijuana through legal means, so he began growing his own. He later was tried and convicted for possession. On appeal, the First District reversed on grounds that Sowell could use "medical necessity" as a valid defense against the drug charges.