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Testing 123 Link

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Statehouse, Supreme Court Courtroom, 200 West Washington Street, Indianapolis, IN 46204

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.

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