Attorneys for a Manchester Township man accused of killing his on-again, off-again girlfriend have filed a pre-trial motion arguing the man shouldn't face the death penalty in the case.

Northern York County Regional Police said 42-year-old Ross William Crawford killed Cherylann Jennifer Dowell, 53, inside her 507 Cedar Village Drive home by hitting her on the head.

When prosecutors filed notice of their intention to seek the death penalty on July 24, chief deputy prosecutor Jennifer Russell said there was one aggravating factor for which the death penalty would apply: At the time of the murder, Crawford was subject to a court order prohibiting him from having any abusive contact toward Dowell.

In Pennsylvania, prosecutors must present "aggravating factors" to argue for a death sentence.

In the motion filed Monday, senior assistant public defender Erin Thompson and private attorney Jeffrey Marshall argued to have the aggravating factor quashed, removing the cause for a death-penalty case.

Court documents reveal Crawford and Dowell had a tumultuous, on-again, off-again relationship. Police arrested Crawford a number of times over the past three years for alleged crimes against Dowell, including aggravated assault, arson, burglary, making terroristic threats, theft and other offenses.

Crawford was, after pleading guilty to charges in March 2011, ordered to have no contact with Dowell. But the defense attorneys argue that Crawford wasn't given a no-contact order during his last appearance in court, May 21, 2012, his last appearance before Dowell was killed.

Lishani Sunday, senior deputy prosecutor, said prosecutors are "opposed to everything they have in that motion."

"The fact of the matter is he was told to have no abusive contact ... as part of the original (2011) case," she said. "Part of the sentencing was that he not have contact for as long as he was on supervision (probation) for that case."

Crawford was sentenced to three years' probation after the March 2011 guilty plea.

As is common for capital cases, defense attorneys moved to have the case tried as non-capital case by questioning the constitutionality of the death penalty and claiming the death penalty is cruel and unusual punishment. Such motions are typically dismissed.

Common Pleas Judge Gregory M. Snyder has been assigned the case. Sunday said a hearing will be scheduled to air the pre-trial filings after her office responds to the defense's motions. Crawford remains in York County Prison without bail, charged with first-degree murder and stalking.

The background: Dowell's body, covered with a blanket and towel, was found June 8 by a concerned co-worker, who fled the Manchester Township home after encountering a blood-covered and knife-wielding Crawford, police said.

When officers arrived and arrested Crawford, they discovered he'd inflicted numerous knife injuries to his own arms and neck in a botched suicide attempt, police said. They also found signs of a struggle, with furniture toppled and picture frames broken, court documents state.

Crawford left a number of notes in Dowell's home, according to documents; one stated, "I Love Life. But my true love is gone and got to join her."

He'd been out of prison for less than three weeks when Dowell was killed and was supposed to be on house arrest, according to court records, but his electronic monitoring had not yet been set up.

- Staff writer Liz Evans Scolforo contributed to this report. Reach Christina Kauffman at