Fontae Buelow Case: Two Trials, Supreme Court Ruling, Appeal

The Fontae Buelow case is the Iowa prosecution of Fontae Cole Buelow, a Dubuque man convicted twice of second-degree murder for the March 2017 stabbing death of his 21-year-old girlfriend, Samantha Link. Between the two trials, the Iowa Supreme Court used his appeal to rewrite how Iowa courts treat a victim’s mental health history when a defendant claims the death was suicide. Buelow is now serving a 50-year sentence at the Fort Dodge Correctional Facility.¹

What Happened the Night Samantha Link Died

On the night of March 30, 2017, Buelow, then 25, and Link spent the evening at a hotel hot tub and then a bar, where they began arguing. The argument continued after they returned to the Dubuque home they shared in a friend’s basement on Kane Street. No one else was in the residence.²

In the early hours of March 31, Buelow called 911 and told the operator that Link had stabbed herself in the stomach. Responders pronounced her dead at the scene. The autopsy found three stab wounds to the chest rather than the single stomach wound Buelow described. Two of the three were independently fatal, striking her heart and a lung.²

Link had been diagnosed with bipolar disorder, borderline personality disorder, and depression, and had a documented history of suicide attempts and suicidal ideation. Those diagnoses would become the center of the legal fight over how she died.³

The First Trial and What the Jury Never Heard

The State charged Buelow with first-degree murder. His only defense was that Link had taken a knife from a butcher’s block on the kitchen counter and stabbed herself while he was trying to end the relationship.⁴

To support that theory, the defense wanted to put Link’s mental health and counseling records in front of the jury. The district court refused. The defense’s psychiatric expert, Dr. David Bean, was limited to records from the single year before Link’s death and was barred from opining on whether her suicidal behavior may have escalated the night she died. Her broader medical records were excluded entirely. Lay testimony about her suicidal disposition was also blocked, including testimony from a former boyfriend who said Link had once grabbed a knife during an argument in their relationship.⁵

What the jury did hear was the forensic case for homicide. State Medical Examiner Dennis Klein testified that the wounds were inconsistent with suicide: they ran vertically rather than horizontally as self-inflicted chest wounds typically do, Link had two long, deep cuts on her right hand consistent with defensive injuries, the knife was found eight to twelve feet from her body, and her sweatshirts showed sharp-force damage consistent with being stabbed through clothing. Klein also testified that stabbing oneself more than once is unusual.⁶

In January 2018, the jury returned a verdict of second-degree murder rather than first, and Buelow was sentenced to 50 years.⁴

The Iowa Supreme Court Ruling

Buelow appealed, arguing the exclusions had gutted his only defense. In December 2019, the Iowa Court of Appeals reversed the conviction and ordered a new trial.⁷ The State sought further review, and on December 11, 2020, the Iowa Supreme Court affirmed the reversal.

The ruling reshaped Iowa evidence law in two ways. First, the court held that evidence of a person’s suicidal disposition is not “character evidence” under the Iowa Rules of Evidence, so it is not subject to the restrictions of Rule 5.404(b). Second, the court rejected the argument that records from roughly three years before Link’s death were too remote to matter. Chief Justice Susan Christensen wrote: “For a young woman of 21, suicide attempts and mental health diagnoses from a few years prior are clearly relevant to the question of whether she took her own life or was killed by Buelow.” The exclusion was not harmless, the court concluded, because the State’s evidence was not overwhelming and Buelow had been left without his only theory of defense.²

The Second Trial With the Full Defense

Buelow was retried in Clinton County in June 2021, this time with the mental health evidence in play. A forensic psychiatrist testified for the defense that Link had been diagnosed with borderline personality disorder, multiple substance abuse disorders, and a history of self-harm and trauma, and was at “high risk for chronic suicide.”⁸

Forensic pathologist Dr. Bradley Randall testified for the defense that the circumstances were more suggestive of suicide than homicide. Defense attorneys stressed that no DNA evidence connected Buelow to the knife and that fingerprints on the weapon matched his account of how Link had held it.⁹ A defense blood spatter consultant placed Buelow at least ten feet away at the time of the stabbing, but on cross-examination conceded Buelow was at “the very outer limits” of the blood’s travel distance and could not explain how the knife came to rest ten to eleven feet away on the living room carpet if the stabbing occurred in the kitchen. Dr. Randall also conceded on cross that he had already concluded the death was a suicide before he reviewed Link’s mental health records.⁸

The prosecution built the same forensic case as before. The medical examiner again ruled the death a homicide, pointing to the absence of hesitation marks, the defensive wounds on Link’s fingers, wound depth reaching 5.5 inches on one strike, and the distance of the knife from the body.⁸

After more than six hours of deliberation, the jury again found Buelow guilty of second-degree murder.¹⁰ On July 15, 2021, he received the same 50-year sentence as before.¹¹

The Bid for a Third Trial

Defense attorneys David Fautsch and Elisabeth Archer immediately moved for a third trial. Their central Miranda claim concerned a statement Buelow made at the scene. After officers handcuffed him, one told him to “relax.” Buelow replied: “Go stab your fucking spouse in the face, then you relax.” The defense argued this was a custodial interrogation without a warning, because Buelow was handcuffed, on his knees, crying, and surrounded by officers.¹²

Dubuque County Judge Monica Zrinyi Ackley denied the motion, writing that “an accused is not entitled to a perfect trial, but only a fair trial.”¹¹

On December 7, 2022, the Iowa Court of Appeals affirmed the second conviction on all counts. It held that the officer’s instruction to “relax” was a routine command during an arrest, not the functional equivalent of interrogation, and that Buelow’s statement was voluntary. The court found the evidence sufficient to support the verdict, noting that the second jury had heard the full suicide defense the Iowa Supreme Court ordered admitted and had still credited the State’s forensic case.⁸ The Iowa Supreme Court declined further review, leaving the conviction and sentence in place.¹³

Innocence Campaign

A Change.org petition titled “Free Fontae Buelow — he is innocent!” has gathered nearly 1,000 signatures. The petition characterizes the case as a wrongful conviction driven by racial bias, describing the jury as all-white, and alleges judicial misconduct by Judge Ackley, who presided over both trials. Supporters have cited a video from the YouTube channel EWU in support of Buelow’s innocence.¹⁴ In her ruling denying a third trial, Judge Ackley wrote that the jury included at least three jurors of mixed ethnicity or who were non-white.¹¹

Where Fontae Buelow Is Today

Buelow is incarcerated at the Fort Dodge Correctional Facility. His second-degree murder conviction carries an 85% mandatory minimum under Iowa law. State corrections records list his parole eligibility as March 30, 2052, and a tentative discharge date of February 3, 2061.¹

1
Iowa Department of Corrections. Offender Detail: Fontae Cole Buelow
2
FindLaw. State v. Buelow, Iowa Supreme Court
3
Disability Memorial. Samantha Link
4
Des Moines Register. Boyfriend Convicted Again in Death of Iowa Woman
5
FindLaw. State v. Buelow, Iowa Court of Appeals
6
KCRG. Medical Examiner Says Wounds Inconsistent With Suicide
7
Iowa Courts. State of Iowa v. Fontae C. Buelow, Case 18-0733
8
FindLaw. State v. Buelow, Iowa Court of Appeals, No. 21-1101
9
KCRG. Man Convicted Twice of Killing His Girlfriend Wants Third Trial
10
KCRG. Buelow Retrial: Found Guilty of Girlfriend’s 2017 Murder
11
Des Moines Register. Fontae Buelow Sentenced to 50 Years in Girlfriend’s Death
12
Des Moines Register. Fontae Buelow Asks for Third Trial in Girlfriend’s Death
13
Telegraph Herald. Iowa Supreme Court Denies Further Review of Buelow Conviction
14
Change.org. Free Fontae Buelow — He Is Innocent