James Johnson a/k/a James Nathaniel Johnson v. State of Mississippi

Court of Appeals of Mississippi·Decided April 21, 2026·No. 2025-KA-00549-COA·Published

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO. 2025-KA-00549-COA

JAMES JOHNSON A/K/A JAMES NATHANIEL APPELLANT JOHNSON

v. STATE OF MISSISSIPPI APPELLEE

DATE OF JUDGMENT: 04/29/2025 TRIAL JUDGE: HON. DEWEY KEY ARTHUR COURT FROM WHICH APPEALED: MADISON COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: OFFICE OF STATE PUBLIC DEFENDER BY: JUSTIN TAYLOR COOK

ATTORNEY FOR APPELLEE: OFFICE OF THE ATTORNEY GENERAL BY: INDIA MARIAH SPRINKLE DISTRICT ATTORNEY: JOHN K. BRAMLETT JR. NATURE OF THE CASE: CRIMINAL - FELONY DISPOSITION: AFFIRMED - 04/21/2026 MOTION FOR REHEARING FILED:

BEFORE BARNES, C.J., McDONALD AND WEDDLE, JJ.

McDONALD, J., FOR THE COURT:

¶1. James Johnson appeals from the Madison County Circuit Court’s re-sentencing order in which the court, following a Miller v. Alabama1 hearing, sentenced Johnson to serve a term of life imprisonment in the custody of the Mississippi Department of Corrections (MDOC) without eligibility for parole. On appeal, Johnson argues that the court misinterpreted the facts and misapplied the law. Having considered the record, arguments of counsel, and relevant precedent, we find no error and affirm the circuit court’s order and

1 567 U.S. 460 (2012).

Johnson’s sentence.

Facts and Procedural History

¶2. In 2001, sixteen-year-old Johnson and his older half-brother, James Howard, robbed a convenience store in Madison County. A jury determined that during the robbery, Johnson shot and killed the store clerk. Johnson was convicted of capital murder in August 2005 and given the only sentence available under Mississippi Code Annotated section 97-3-21 (Rev. 2000) in effect at the time—life imprisonment without parole.2 Johnson appealed, and this

2 Section 97-3-21, “Homicide; penalty for first- or second-degree murder or capital murder,” now provides:

(1) Except as otherwise provided for a juvenile offender in subsection (2) of this section, every person who is:

....

(c) Convicted of capital murder shall be sentenced

(i) to death;

(ii) to imprisonment for life in the State Penitentiary without parole; or

(iii) to imprisonment for life in the State Penitentiary with eligibility for parole as provided in Section 47-7-3(1)(c)(iii).

....

(2)(a) For the purposes of this section, “juvenile offender” means a person who had not reached the age of eighteen (18) years at the time of the commission of the offense.

(b) A juvenile offender who is convicted of first-degree murder after July 1, 2024, may be sentenced to life imprisonment in the custody of the Department of Corrections if the punishment is so fixed by the jury. If the jury fails to fix the penalty at life imprisonment, the court shall fix the penalty at not less than twenty (20) nor more than forty (40) years in the custody of the Department of Corrections.

(c) A juvenile offender who is convicted of capital murder after July 1, 2024, may be sentenced to life imprisonment in the custody of the Department of Corrections or life imprisonment without eligibility for parole in the custody of the Department of Corrections if the punishment is so fixed by the

Court affirmed his conviction and sentence in Johnson v. State, 956 So. 2d 358, 360, 369 (¶1, 27) (Miss. Ct. App. 2007).

¶3. According to the facts as stated in that reported opinion, after the victim was found dead, police discovered a trash can containing three cash drawers similar to those missing from the convenience store. Id. at 361 (¶3). A fingerprint on one matched Johnson’s, and he was arrested and indicted for capital murder. Id. at (¶¶3-4). This fingerprint was the only physical evidence linking Johnson to the crime. Id. at (¶5). But the State also presented witnesses who testified that Johnson and Howard had talked about committing the robbery and that Johnson had confessed to killing the store clerk. Id. On appeal, we found no error by the circuit court in giving the jury instructions or in allowing testimony from witnesses. Id. at 369 (¶26). We affirmed the court’s judgment and Johnson’s sentence of life imprisonment in the custody of MDOC. Id. at (¶27).

¶4. During his incarceration between 2005 and 2016, Johnson was repeatedly cited for violations of prison rules, including threatening an officer and possessing gang paraphernalia and other contraband. He received thirty citations for such behavior over an eleven-year period.

jury. If the jury fails to fix the penalty at life imprisonment or life imprisonment without parole, the court shall fix the penalty at not less than twenty-five (25) nor more than fifty (50) years in the custody of the Department of Corrections.

(d) For a juvenile offender who was convicted of first-degree murder or capital murder prior to July 1, 2024, and who is entitled to a hearing under this subsection, the judge who presided over the trial, or a judge appointed by the senior circuit judge, if the presiding judge is unavailable, shall fix the penalty.

Miss. Code Ann. § 97-3-21 (Supp. 2024).

¶5. In 2012, the United States Supreme Court decided Miller v. Alabama, which held that mandatory sentencing of juveniles to lifetime incarceration without the possibility of parole violates the Eighth Amendment’s ban on cruel and unusual punishment. Miller, 567 U.S. at 479. However, the Supreme Court stated, “Our decision does not categorically bar a penalty for a class of offenders or type of crime . . . . [I]t mandates only that a sentencer follow a certain process—considering an offender’s youth and attendant characteristics—before imposing a particular penalty.” Id. at 483. The factors included in a Miller analysis, which are found in Dotson v. State, 328 So. 3d 659, 667 (¶28) (Miss. Ct. App. 2021), include:

(1) “chronological age and its hallmark features—among them, immaturity, impetuosity, and failure to appreciate risks and consequences”; (2) “family and home environment that surrounds [the defendant]”; (3) “circumstances of the homicide offense, including the extent of his participation in the conduct and the way familial and peer pressures may have affected him”; (4) “that he might have been charged and convicted of a lesser offense if not for incompetencies associated with youth”; and (5) “the possibility of rehabilitation.”

Id. (quoting Miller, 567 U.S. at 477-78).

¶6. Seeing some chance at freedom because of Miller, on January 23, 2013, Johnson filed a motion to obtain the record and transcript of his criminal trial. He later filed a motion to vacate his sentence and requested a re-sentencing hearing because he had committed his crime when he was a juvenile, and he was sentenced under a mandatory sentencing statute as was the defendant in Miller. The circuit court granted Johnson’s petition and vacated his sentence on April 25, 2016. The re-sentencing hearing was set for July 25, 2016, but was subsequently continued several times between that date and one in October 2019.

¶7. In October 2019, Johnson filed a motion for additional time to file a motion for funds

to hire two experts, one in psychology and one in mitigation investigation. The court granted his motion. Johnson also filed a motion for jury sentencing pursuant to this Court’s decision in Wharton v. State, 334 So. 3d 136, 140-41 (¶¶14-15) (Miss. Ct. App. 2018), which held that a Miller re-sentencing hearing could be conducted before a jury. The Mississippi Supreme Court later reversed our decision in Wharton v. State, 298 So. 3d 921, 925 (¶19) (Miss. 2019), and held that a defendant had no constitutional right to have the Miller factors decided by a jury. Johnson later withdrew his motion for jury sentencing.

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