CNN said Los Angeles County Superior Court Judge James Brandlin denied a prosecutor's request that he send the recording artist to jail for violating his probation.
Los Angeles County Deputy District Attorney Mary Murray told the judge Brown is becoming more violent, with his outbursts "increasing in severity and intensity," CNN said.
However, Brandlin cited reports saying Brown is doing well in rehab and may continue his treatment there.
Brown, 24, has been on probation since he pleaded guilty to assaulting his then-girlfriend Rihanna five years ago. He has been arrested several other times for physical altercations with other people, including photographers and bar patrons.
He entered rehab last November when the judge gave him the choice of treatment or jail for an earlier probation violation.