By Jim Thomas
Tuesday, June 16, 2026
A federal judge in Milwaukee has refused to throw out former Wisconsin Circuit Judge Hannah Dugan’s felony obstruction conviction, clearing the way for sentencing in a case that became an early flash point in the Trump administration’s courthouse immigration arrests.
U.S. District Judge Lynn Adelman denied Dugan’s motion for reconsideration in a 32-page order, ruling that her conduct on April 18, 2025—when she led Mexican national Eduardo Flores-Ruiz out of a private jury door while federal immigration agents waited in the corridor—obstructed a “pending proceeding” under 18 U.S.C. Section 1505.
Adelman, who was appointed by former President Bill Clinton, did not reset a sentencing date.
Dugan’s lawyers had sought reconsideration after the 4th U.S. Circuit Court of Appeals split 2-1 in April to vacate a conviction in United States v. Hernandez, holding that Immigration and Customs Enforcement’s execution of an already-issued removal order did not count as a “pending proceeding” under the statute.
Dugan’s legal team called Adelman’s decision “wrong.”
Adelman drew a sharp factual line: In Hernandez, ICE was finishing up a job after another agency had ordered removal. Here, she wrote that ICE was still investigating, securing probable cause, and seeking to arrest Flores-Ruiz before any removal order was reinstated.
“This case did not involve some random encounter on the street,” Adelman said in her order. “It was a targeted operation, conducted pursuant to agency procedures, including the issuance of an arrest warrant for a specific person, Eduardo Flores-Ruiz.”
The judge also rejected Dugan’s defense claim that ICE arrests are indistinguishable from routine police work.
“Unlike, say, the FBI, ICE can issue its own warrants and adjudicate and effectuate removal without court involvement,” Adelman wrote. “This makes a difference under section 1505.”
A jury convicted Dugan, 67, on December 19 of the obstruction felony and acquitted her of a misdemeanor concealment charge.
Dugan resigned from the Milwaukee County Circuit Court two weeks later, after nine years on the bench, amid impeachment threats from Republican state lawmakers.
She faces up to five years in prison, though federal guidelines typically call for probation for first-time, nonviolent offenders.
Flores-Ruiz pleaded guilty to illegal reentry and was deported on November 13, 2025.
The case is widely expected to reach the 7th U.S. Circuit Court of Appeals after sentencing.
