The defense team for the man accused in the slaying of a Union woman continued to argue that the most the man could be convicted of is second-degree murder due to his mental state.

A written memorandum submitted to the court states Timothy D. Shults showed “psychotic features” but his mental state during the murder has not been determined.

The memorandum, requested by Judge Gael Wood at the conclusion of the trial, was submitted by a public defender Robert Wolfrum.

Wolfrum argues that Shults did not exhibit cool deliberation — required in a first-degree murder conviction — during the murder of Deborah Marsch, 53, Union.

Shults, 47, is charged with first-degree murder in the death of Marsch, who was strangled to death July 3, 2009, in Union’s Autumn Hill Park.

The murder was an apparent random act of violence, authorities said.

The Franklin County Prosecutor’s Office is expected to answer the claims in the memorandum.

A bench trial in front of Wood was held June 29 through July 1. Judge Wood did not say when he would issue a verdict.

Shults recently waived a jury trial and is being tried in a bench trial before Judge Wood. In exchange for waiving a jury trial, the prosecutor’s office agreed to not seek the death penalty for Shults.

In the memorandum, Wolfram said Shults suffered a personality change, and that claim was “uncontested” by the state’s expert witness Dr. John Rabun.

In an effort for a ruling of the lesser conviction of second-degree murder, Wolfrum has argued that Shults’ actions were triggered by psychological problem resulting, in part, from a “traumatic brain injury” he suffered in May 2000 after falling through a floor while working at a construction site.

Wolfrum further states in the memorandum that the state did not prove deliberation beyond a reasonable doubt during trial.

According to reports, Shults confessed to police on Sunday, July 5, 2009, that he killed the woman, then took detectives to the location where he dumped her body off Judith Spring Road.

During police interviews, the suspect said he did not know Marsch but that he was angry and she was “in the wrong place at the wrong time.”

Shults also is charged in a separate case with burglary, kidnapping, armed criminal action and violation of an order of protection. A trial on those charges has not yet been scheduled.

Authorities allege that the day after the murder Shults broke into his estranged wife’s home in Washington, waited for her to return, then told her that he wanted her to go with him and she consented. He drove her car to the Labadie area and told her to walk with him into the woods but she refused and eventually convinced him to release her, authorities allege.

Later Saturday, after the abduction was reported, Washington police began an investigation and on Sunday contacted Union police who were familiar with Shults and his ex-wife who lives in Union.

Detectives went to the ex-wife’s home and found Shults there, according to police.