James L. Johnson, Jr. v. State of Mississippi, 204 So. 3d 817

James L. Johnson Jr. was tried in Alcorn County for aggravated domestic violence by strangulation against his ex-wife, Volante Jones, for an incident on December 3, 2012; a jury convicted him and he was sentenced to 20 years (10 to serve).
The State proffered four prior bad acts spanning 1999–2012 (two prior simple-assault convictions and two unprosecuted/dismissed domestic-violence incidents involving three other women and the victim’s daughter) to rebut Johnson’s self-defense claim and to show intent/motive/plan.
At trial the State introduced the full police offense reports for those incidents and two convictions; those reports contained more serious and additional allegations than the State’s original pretrial proffer.
The trial court admitted the entire contents of the four offense reports over defense objections, without re-evaluating whether the additional allegations in the reports satisfied M.R.E. 404(b) purposes or survived a Rule 403 probative-vs.-prejudice balancing test.
Johnson appealed, arguing improper admission of prior-bad-acts evidence; the Court of Appeals reversed and remanded, finding abuse of discretion in admitting the unredacted reports.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Johnson)	Held
Admissibility of prior-bad-acts evidence	Proffered four prior incidents to show intent, motive, plan and to rebut self-defense; relevant and probative	Admission prejudiced Johnson because reports contained additional, inflammatory allegations beyond the proffer and outweighed probative value	Reversed — court abused discretion by admitting full offense reports without 404(b) purpose analysis and fresh Rule 403 balancing
Use of offense reports vs. proffer	State argued details in reports supported the proffered purposes and were proper to show history of violence against women	Johnson argued State never amended proffer to include full report contents; reports contained allegations exceeding proffer	Held inadmissible in full absent proper proffer and balancing; reports should have been screened/redacted
Preservation of objection	State contended pretrial ruling allowed use of prior acts; trial admission was consistent with pretrial ruling	Johnson preserved objections by motion in limine and continuing objections at trial	Court noted objections were preserved but admission nonetheless reversible error
Remedy	State implicitly urged harmless-error standard	Johnson sought reversal and retrial due to prejudicial evidence	Reversed and remanded for new proceedings; appellate court declined to address other claims

Welde v. State, 3 So. 3d 113 (Miss. 2009) (trial court must evaluate 404(b) purpose and perform Rule 403 balancing before admitting other-bad-acts evidence)
Stone v. State, 94 So. 3d 1078 (Miss. 2012) (appellate review of evidentiary rulings is for abuse of discretion)
Lesley v. State, 606 So. 2d 1084 (Miss. 1992) (discusses admissibility of other-crimes evidence and Rule 403 analysis)
Mack v. State, 650 So. 2d 1289 (Miss. 1994) (analysis of when other-crimes evidence is admissible)
Pruitt v. State, 807 So. 2d 1236 (Miss. 2002) (approving redaction of documents to remove references to past crimes when appropriate)