In this paper we examine the geometrically constrained optimization approach to localization with hybrid bearing (angle of arrival, AOA) and time difference of arrival (TDOA) sensors. In particular, we formulate a constraint on the measurement errors which is then used along with constraint-based optimization tools in order to estimate the maximum likelihood values of the errors given an appropriate cost function. In particular we focus on deriving a localization algorithm for stationary target localization in the so-called adverse localization geometries where the relative positioning of the sensors and the target do not readily permit accurate or convergent localization using traditional approaches. We illustrate this point via simulation and we compare our approach to a number of different techniques that are discussed in the literature.