Haile v. State, 431 Md. 448

Haile stabbed Sims; police linked Haile as suspect and pursued him after he fled.
Bennie, a police canine, bit Haile; Haile struck Bennie, injuring the dog.
At trial, state rested; defense moved for judgment of acquittal, which was denied; Haile testified he did not recall striking Bennie.
Haile was convicted of first-degree assault and aggravated cruelty to animals; sentenced to consecutive terms.
Court of Special Appeals affirmed; Maryland Court of Appeals granted certiorari to review sufficiency and ineffective assistance claims.
Issue framing: sufficiency of evidence for aggravated cruelty and effectiveness of counsel for failing to renew motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for aggravated cruelty to animals?	Haile argues lack of specific intent and de minimis harm negate § 10-606(a)(3).	State contends plain language covers all bodily harm; no need for specific intent; self-defense not proven.	Evidence sufficient; rational jury could find guilt beyond reasonable doubt.
Did counsel's failure to renew the motion for acquittal amount to ineffective assistance?	Failure to renew after defense case precludes review; claim should prevail.	Procedural rules bar sufficiency review absent renewal; not automatically ineffective assistance.	Court declines to decide on ineffectiveness; decision rests on sufficiency, which supports conviction.

Ennis v. State, 306 Md. 579 (Md. 1986) (failure to renew judgment of acquittal bars sufficiency review)
Chen v. State, 370 Md. 99 (Md. 2002) (distinguishes specific vs. general intent in intent crimes)
State v. Smith, 374 Md. 527 (Md. 2003) (standard for sufficiency review; rational trier could convict)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency standard for evidence in criminal trials)
Tull v. State, 230 Md. 152 (Md. 1962) (renewal requirement for sufficiency review)
Roach v. State, 358 Md. 418 (Md. 2000) (self-defense elements and provocation framework)