State v. Burnett

2025 Ohio 1836
CourtOhio Court of Appeals
DecidedMay 22, 2025
Docket114495
StatusPublished

This text of 2025 Ohio 1836 (State v. Burnett) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Burnett, 2025 Ohio 1836 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Burnett, 2025-Ohio-1836.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO,

Plaintiff-Appellee, : No. 114495 : v. : HALIMAH BURNETT, : Defendant-Appellant.

JOURNAL ENTRY AND OPINION

JUDGMENT: REVERSED AND VACATED RELEASED AND JOURNALIZED: May 22, 2025

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-24-692636-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, Sarah Hutnik and Dominic Neville, Assistant Prosecuting Attorneys, for appellee.

Cullen Sweeney, Cuyahoga County Public Defender, and Rick L. Ferrara, Assistant Public Defender, for appellant.

EMANUELLA D. GROVES, J.:

Defendant-appellant Halimah Burnett (“Burnett”) appeals her

convictions for misuse of credit cards, theft, and theft from a person in a protected class following a jury trial. Upon review, we reverse the judgment, vacate the

conviction, and discharge Burnett.

I. Facts and Procedural History

In June 2024, Burnett was indicted in a three-count indictment for

alleged fifth-degree-felony offenses that occurred on or about January through

February 2024. Count 1 charged Burnett with misuse of credit cards and included a

furthermore specification that the victim of the offense was an elderly person or

disabled adult, and the violation involved less than a $1,000 value. Count 2 charged

Burnett with theft and included a furthermore specification that the property stolen

was a credit card. Count 3 charged Burnett with theft from a person in a protected

class and included a furthermore specification that the victim of the offense was a

disabled adult or active-duty service member or spouse. Burnett pleaded not guilty,

and the matter proceeded to trial in September 2024.

The following evidence was presented by the State. Mayfield Village

Patrolman Steven Palka (“Officer Palka”) received a report from Via Quest1

Operations Manager Aaron Walker (“Walker”) on February 20, 2024, regarding the

misuse of a credit card. According to Officer Palka, Walker reported that fraudulent

activity appeared on the checking account of one of his Via Quest clients (“the

client”), who was autistic, nonverbal, and deaf. Officer Palka identified Burnett as

the suspect without elaborating as to how she was identified. When Officer Palka

1 Officer Palka described Via Quest as a “healthcare company that provides 24/7

healthcare needs [for] people with developmental disabilities.” (Tr. 209.) took Walker’s report, he was given screenshots and the client’s checking-account

statements. The screenshots (“text-message receipt”) documented a text message

from Burnett to Walker with a receipt for an “authorized purchase” of groceries on

January 14, 2024, totaling $90. (Tr. 211.) Burnett’s text-message receipt confirmed

that she placed the client’s order on a Door Dash account and showed the items

purchased as well as the total paid by the client — all of which were “approved.” Id.

at 211-213. In his independent review of the client’s checking-account statements,

Officer Palka noticed multiple additional Door Dash orders. Aside from taking

Walker’s report, Officer Palka was not otherwise involved in the investigation.

Next, Walker offered testimony regarding Via Quest’s operations,

Burnett’s Via Quest employment, and the circumstances surrounding his report to

Officer Palka. Walker explained that in addition to other services, Via Quest

provides the following financial assistance to individuals with developmental

disabilities:

So [clients] can ask — well, they work with a support administrator, somebody from the county, so if they don’t have an understanding or the concept of money then they need a payee. So with Via Quest we offer that service also. So myself as operations manager, I can give directive[s] to management underneath me or to staff to say, hey, you know, here is a debit card or here’s cash so that we can, you know, make sure that the clients have everything that they need in the house. We take care of all their bills. If they’re paying rent anything that comes through as far as like [M]edicaid we take care of everything for the most part.

Id. at 222. Walker testified that he was one of the individuals responsible for the

client’s financials, including her debit card. Walker advised that the Via Quest

manager or staff member in possession of the client’s physical debit card was the

only person authorized to use it, explaining:

[W]hen an individual comes [to Via Quest] they do an assessment to see how they understand the concept of money. And you know, if they’re not able to carry their debit card because they’ll just swipe, swipe, swipe or somebody could take advantage of them so we hold on to the debit card and we’ll put in their plan they might be able to hold ten dollars or cash per week and then we keep that ten dollars of cash on them and then anything else we keep up with all of these things and then we get permission to use the card once it hits [a] certain amount for like big purchases.

Id. at 225.

Walker further testified that Burnett worked under him as a direct-

support professional for Via Quest and had access to the client’s debit card. Walker

advised that Burnett was approved to use the debit card on one occasion after she

volunteered to do the client’s grocery shopping for him. Walker explained Via

Quest’s shopping process as follows:

So usually staff or even myself will go into the home, we’ll say, you know, they need groceries or even the client might say they need something they want that’s not in the home, we didn’t purchase this particular time they just need to do re-up on all their groceries.

So we didn’t give the card out to all of the staff because we don’t want fraud to happen or cards get misplaced or different things like that. So if there’s a staff that’s been working at the site who’s trained at the site who knows the individuals and what they like to eat, we’ll allow them to go grocery shopping. So they’ll [make] a list. I have — I had the staff do a list with the other staff and with the individuals to make sure that they are getting what they like to eat and what they want to take to their day program. Once that list is done they’ll let me know, hey, I’m about to go grocery shopping. I’ll say, okay, make it an outing so that the individuals are participating. If it’s a rough day the staff will do it on their own. This particular time it was done through Door Dash which we don’t like Door Dash because we have to pay for fees and an unnecessary fee the clients have to pay so we rather our staff go to the store. But this particular time was Door Dashed. I’m not sure if the clients were having a bad day or it was just easier at the time. So the purchases get made, staff will let me know, you know, make the purchases, and then they’ll send me a picture of the receipt to show that these are all the purchases and this is how much was spent.

Usually when I have enough time I’ll go back to the site just to make sure that whatever was on the receipt matches what’s in the home and then I turn in the receipts to my — well, I upload the receipts to a system that we use to do our audits. My boss will sign off on all the receipts. I match it with what was spent from the bank account and everything is signed off and then then we close it off for the whole entire month and then we re-up the debit card or bank account with the funds that are coming in from their benefits such as social security or something like that.

Id. at 226-228.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1836, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-burnett-ohioctapp-2025.