State v. Hillyer

2025 S.D. 30
CourtSouth Dakota Supreme Court
DecidedJune 25, 2025
Docket30444
StatusPublished

This text of 2025 S.D. 30 (State v. Hillyer) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Hillyer, 2025 S.D. 30 (S.D. 2025).

Opinion

#30444-a-JMK 2025 S.D. 30

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

STATE OF SOUTH DAKOTA, Plaintiff and Appellee,

v.

RICHARD LEE HILLYER, Defendant and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT PENNINGTON COUNTY, SOUTH DAKOTA

THE HONORABLE CRAIG A. PFEIFLE Retired Judge

CONOR DUFFY of Duffy Law Firm Rapid City, South Dakota Attorneys for defendant and appellant.

MARTY J. JACKLEY Attorney General

SHALE R. KRAMME Assistant Attorney General Pierre, South Dakota Attorneys for plaintiff and appellee.

CONSIDERED ON BRIEFS JUNE 4, 2024 OPINION FILED 06/25/25 #30444

KERN, Justice

[¶1.] After a one-day jury trial, Richard Hillyer was convicted of possession

of a weapon—an altered razor blade—by an inmate of a jail in violation of SDCL 24-

11-47(3). Hillyer appeals his conviction, arguing that the circuit court erred by

rejecting his lesser-included offense jury instruction, denying his motion for

judgment of acquittal based on insufficient evidence, and refusing to give an

instruction telling the jury not to consider hypothetical uses of the razor blade.

Additionally, he asserts that the cumulative effect of these errors deprived him of a

fair trial. We affirm.

Factual and Procedural Background

[¶2.] In September 2022, while an inmate at the Pennington County Jail,

Richard Hillyer checked out a jail-issued shaving razor. Hillyer removed the blade

from the plastic housing and broke the blade in half. He flushed one-half of the

razor blade down the toilet and wrapped the other half in tape and hid it in his

mouth. Hillyer maintains he kept the blade, not to injure anyone else, but only to

cut himself, a practice he claims he has been doing since he was a teenager to

relieve his anxiety.

[¶3.] When Hillyer failed to return the razor to jail staff, they suspected he

may have concealed it and moved him to a holding cell where he could be more

closely observed. On September 11, 2022, while speaking with Sergeant James

Hogue, Hillyer admitted he had the razor blade, removed it from his mouth, and

gave it to Sergeant Hogue. Hillyer then told Sergeant Hogue that he had the blade

to “manipulate housing”—to be moved to a cell where he would have a view of the

-1- #30444

television. The half of the razor blade Hillyer gave to Sergeant Hogue was turned

over to Deputy Mooney with the Pennington County Sheriff’s Office. Hillyer told

Deputy Mooney that he kept the razor blade to cut himself in an attempt to get

moved to a different cell. The other half of the razor blade was never found.

[¶4.] Hillyer was charged with possession of weapons in jail, in violation of

SDCL 24-11-47(3), a Class 2 felony. The State filed an amended part II

information, charging him as a habitual offender based on four prior felonies.

Hillyer pled not guilty and demanded a jury trial.

[¶5.] At trial, the State called Sergeant Hogue who testified that razors are

issued to inmates who are allowed approximately 45 minutes to shave, after which,

they must turn in the razor. He testified the process for checking razors out and

back in is to make sure the razors are accounted for, as there is concern that

inmates could use the razors for “nefarious actions such as making weapons.”

Sergeant Hogue testified that in his experience at the Pennington County Jail, he

has seen inmates use razor blades in a variety of ways, including as a weapon. He

also testified that based on the condition of the razor blade when Hillyer removed it

from his mouth, it could be used as a weapon by “holding it in your fingers to cut at

somebody.” Sergeant Hogue explained:

Holding a razor blade in your fingers is definitely – can be used as a weapon. I don’t want to – I don’t want to find anybody that has a razor blade regardless of the size, you know. I don’t want to interact with somebody that may have a potential weapon of that sort.

Sergeant Hogue testified that to be “most effective” the razor blade would have to be

attached to a handle, but that it could be used as a weapon without one. The razor

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blade that Hillyer possessed was admitted as an exhibit, passed around to the jury,

and taken to the jury room during the jury’s deliberations.

[¶6.] After the State rested, Hillyer moved for judgment of acquittal,

claiming there was no evidence the razor blade “was used to inflict death or serious

bodily harm.” Defense counsel stated the only evidence presented was that the

razor blade was “designed to make small cuts on the insides of [Hillyer’s] calves.”

Counsel argued:

There has been no evidence presented in the State’s case-in-chief that would satisfy the statutory definition of weapon for that razor blade. Even the sergeant testified that it would have to – something else would have to be attached for it to be effectively used as a weapon.

Given that because this was not used as a weapon, it was not used in a manner that was likely to inflict death or serious bodily harm and it was not designed to do so, the State at this point has failed to meet its burden and I would ask for a judgment of acquittal because no reasonable juror could find that that piece of razor meets this definition.

The State argued that whether the razor blade met the statutory definition of

dangerous or deadly weapon was for the jury to decide. The circuit court denied the

motion for judgment of acquittal.

[¶7.] Hillyer testified in his own defense and admitted that he made the

“conscious choice to break the razor blade that the jail issued [to him].” He

maintained that he never intended to hurt anyone else with the razor blade and

that he broke the razor blade in half because he “only needed a little piece to cut

[him]self.” He admitted he made “some superficial cuts” on himself with the razor

blade.

-3- #30444

[¶8.] When the circuit court and counsel settled the jury instructions,

defense counsel proposed a lesser-included instruction for misdemeanor possession

of an unauthorized item in jail, a violation of SDCL 24-11-47.1.1 The circuit court

applied the elements test set forth in State v. Willingham, 2019 S.D. 55, 933 N.W.2d

619, in determining that the lesser-included instruction was not warranted,

explaining:

Number one, all the elements of the included offense are fewer in number than the elements of the greater offense.

Number two, the penalty for the lesser-included offense must be less than that of the greater offense.

And number three, both offenses must contain common elements so that the greater offense cannot be committed without committing the lesser offense.

In this particular case, I don’t believe the lesser-included instruction specifically meets element number 3, that there are common elements so that the greater offense cannot be committed without committing the lesser offense.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 S.D. 30, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hillyer-sd-2025.