Judge Upholds Hannah Dugan Conviction for Helping Immigrant Evade ICE, June 17

U.S. District Judge Lynn Adelman upheld the felony obstruction conviction of former Milwaukee County Judge Hannah Dugan on June 16. Dugan was convicted of helping undocumented immigrant Eduardo Flores-Ruiz evade ICE agents at a courthouse on April 18, 2025. The ruling marks a key moment in how courts interpret obstruction laws during the Trump administration’s immigration enforcement push.

What Dugan Did and Why She Was Charged

Dugan confronted ICE agents who arrived at her Milwaukee courtroom with an arrest warrant for Flores-Ruiz, a man deported in 2013 who returned without permission. She told agents their administrative warrant was insufficient and led Flores-Ruiz and his attorney out through a private jury door. A jury convicted her in December 2025 of obstructing ICE officers but acquitted her on a lesser charge of concealing someone set for deportation.

Why Dugan’s Defense Failed

Dugan’s legal team argued that ICE enforcement actions do not qualify as “pending proceedings” under federal obstruction law. They relied on a Virginia appeals court decision from April 2026 that narrowed what counts as a proceeding. Judge Adelman rejected this argument, writing that ICE’s targeted operation with an arrest warrant differed from the Virginia case. Unlike that case, where a deportation order already existed, ICE was still investigating Flores-Ruiz and determining whether his prior deportation order should be reinstated.

The Legal Standard for ICE Actions

Adelman ruled that ICE enforcement qualifies as an agency proceeding protected by obstruction law. He noted that ICE can issue its own warrants and make removal decisions without court involvement, unlike the FBI. The judge pointed to rulings from federal appeals courts that SEC enforcement of securities laws and IRS collection of tax debts also qualify as protected proceedings. Dugan faces up to five years in prison but is likely to receive probation given her lack of criminal history and nonviolent conviction.

What Happens Next

Judge Adelman did not immediately set a sentencing date after upholding the conviction. Dugan resigned from the Milwaukee County Circuit Court following her conviction and faced impeachment threats from state Republicans. Her legal team stated in response to the ruling that “the court’s decision is wrong.” The case remains an early test of how federal courts apply obstruction law to judicial actions during immigration enforcement operations.

Final Thoughts

Dugan’s conviction stands despite her legal challenge. The ruling signals that courts will enforce obstruction laws against judges who interfere with ICE operations, even in courtroom settings.

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