It’s actually quite possible to live through a head shot, especially since, considering the time frame of the movie being in the early '90s, most cops out in California were armed with either 9mm’s or .38’s, neither of which are really adequate combat rounds unless in the hands of a professional. In most cases involving these two rounds, it’s not uncommon for the bullet to travel under the scalp, and exit on the other side of the head. In Mr. Brown’s case, it probably entered, moved along the inside of his skull, and stayed there. Probably could of survived for a few minutes with that kind of wound.
