Federal Judge Upholds Obstruction Conviction of Former Wisconsin Judge Hannah Dugan

A federal judge in Wisconsin ruled Tuesday that the obstruction of justice conviction of former Milwaukee County Circuit Court Judge Hannah Dugan will stand, rejecting efforts to have the verdict thrown out.

Dugan’s case drew national attention as one of the first major legal tests of how courts would respond to President Donald Trump’s aggressive immigration enforcement push. Trump’s allies labeled her an activist judge, while those who supported her argued she was being unfairly singled out.

U.S. District Judge Lynn Adelman had delayed Dugan’s sentencing on June 3 to weigh arguments over whether the conviction should be overturned. On Tuesday, Adelman issued his ruling — the conviction stays. He did not announce a new sentencing date.

Dugan’s legal team wasted no time responding. “The court’s decision is wrong,” her defense attorneys said in a statement.

Her attorney had argued the conviction should be invalidated because a federal appeals court in April struck down a key ruling in a Virginia immigration case that had been cited by both the judge and prosecutors during Dugan’s trial. In that Virginia case, an undocumented immigrant who had been detained by U.S. Immigration and Customs Enforcement agents later escaped, was recaptured, and was charged with obstructing a pending immigration proceeding. The appeals court determined that the ICE action in that case did not meet the legal definition of a “pending proceeding” under federal obstruction law.

Dugan’s attorneys applied the same reasoning to her situation, arguing that because ICE agents at the Milwaukee courthouse only had an administrative arrest warrant — not a formal court proceeding — there was no “pending proceeding” to obstruct. Therefore, they contended, the charge against her was invalid.

Prosecutors pushed back, saying the facts in the Virginia case are distinct from Dugan’s and that other legal precedents support her conviction.

Judge Adelman agreed with prosecutors, ruling that the attempted arrest of the immigrant, Eduardo Flores-Ruiz, did qualify as a “pending proceeding.” He noted a key distinction: the ICE operation was a planned, targeted effort — not a random encounter.

“Defendant argues that ICE was acting as a law enforcement agency here,” Adelman wrote in his ruling. “But this ignores the fact that, unlike, say, the FBI, ICE can issue its own warrants and adjudicate and effectuate a removal, as it did with Flores-Ruiz, without the involvement of a court. This makes a difference.”

Dugan, 67, was convicted by a jury on December 19 and faces a maximum sentence of five years in prison. However, legal experts note she is unlikely to serve any time, as federal sentencing guidelines typically call for probation in cases involving defendants with no prior criminal record who are convicted of nonviolent offenses.

She resigned from the bench two weeks after her conviction amid calls for her impeachment from Republican state lawmakers. She had served as a judge for nine years.

The events that led to her arrest unfolded on April 18, 2025, when immigration officers arrived at the Milwaukee County courthouse. They had learned that Flores-Ruiz, who had reentered the country illegally, was scheduled to appear before Dugan for a hearing in a state battery case.

Dugan confronted the agents outside her courtroom and directed them to the chief judge’s office, telling them their administrative warrant was not sufficient grounds to detain Flores-Ruiz. After the agents left, she guided Flores-Ruiz and his attorney out through a private jury door. Agents spotted Flores-Ruiz in a hallway, pursued him outside, and arrested him following a foot chase. One week later, FBI agents arrested Dugan inside the courthouse, escorting her out in handcuffs.

Dugan’s case was historic — it marked the first time a Wisconsin state judge had gone to trial on charges of obstructing immigration agents. She was acquitted on a separate misdemeanor charge of concealing an individual to prevent arrest. Flores-Ruiz was deported in November.