Zachariah Konkle fought Michael Steele, and Steele died. The State charged Konkle with murder in Jackson Circuit Court. Konkle argued he was guilty of a lesser-included offense instead of murder because he did not know Steele had a heart condition. The State argued-for the first time-in closing argument that Steele was an "eggshell victim," which would make Konkle guilty even if he didn't intend to kill Steele. A jury found Konkle guilty of voluntary manslaughter. The Court of Appeals held the State's closing argument was prosecutorial misconduct, reversed Konkle's conviction, and remanded for a new trial. Konkle v. State, 227 N.E.3d 212 (Ind. Ct. App. 2024), vacated. The Indiana Supreme Court has granted the State's petition to transfer and assumed jurisdiction over the case.