Reminds me of another “slow client”-related bug in gunicorn: https://github.com/benoitc/gunicorn/issues/3334
https://datatracker.ietf.org/doc/html/rfc9112#section-9.6 (this was already in https://datatracker.ietf.org/doc/html/rfc7230#section-6.6)
The relevant condition here is where one side closed its socket but the other side didn't and keeps sending data to the closed socket. That's obviously an improper way to end a connection. A graceful shutdown does not send RST and ensures all data is received on both sides.