Brown was stopped by police after they saw him bang on the window of a car stopped at a red light. He had his hands in his pockets, and an officer asked him to remove them. When Brown made a move the officer viewed as suspicious, the officer tried to grab his hands. A scuffle ensue. Brown was arrested and searched, and officers found marijuana and cocaine on him. The trial court found this evidence admissible, and Brown was convicted of possession. His conviction was affirmed by the Fourth District.