 He was the backup to John Dutton for San Jose's playoff run, but did not play.Dutton had been Brown's backup at Texas and had transferred to Nevada after the 1995 season when it became clear he would not win the starting position.In 2003 Brown was signed again by the Georgia Force, but he only played in two games before leaving the league for the NFL Europe, but he started the second game in place of the injured Donnie Davis and led the team to an upset win over San Jose, becoming the game's MVP.