Brown v. State

Summary

The Court affirmed Brown’s convictions and sentences, holding that the officer had probable cause to arrest him for driving after judgment prohibited and that the ensuing search of his person was valid as a search incident to arrest. The Court declined to reach Brown’s separate state constitutional challenge because it was not fairly presented below, and it rejected his due process challenge to the sentence because the sentence was within the statutory limits and reflected aggravating and mitigating factors.