Former Judge's ICE Obstruction Conviction Upheld

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A federal judge in Milwaukee refused Tuesday to throw out former Wisconsin Circuit Judge Hannah Dugan's felony obstruction conviction, clearing the way to 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 Eduardo Flores-Ruiz, a Mexican national, out a private jury door while federal immigration agents waited in the corridor, obstructed a "pending proceeding" within the meaning of 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 pressed Adelman to reconsider 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 Tuesday's decision "wrong."

Adelman, however, drew a sharp factual line.

In Hernandez, ICE was finishing the job after another agency had ordered removal.

Here, Adelman wrote that ICE was still investigating, securing probable cause, and seeking to arrest Flores-Ruiz before any removal order had been reinstated.

"This case did not involve some random encounter on the street," Adelman said in the 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 the defense's broader claim that ICE arrests are indistinguishable from routine police work.

"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," Adelman wrote. "This makes a difference under section 1505."

A jury convicted Dugan, 67, on Dec. 19 of the obstruction felony and acquitted her of a misdemeanor concealment charge.

She 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 Nov. 13, 2025.

The case is widely expected to reach the 7th U.S. Circuit Court of Appeals after sentencing.

The Associated Press contributed to this report.

Jim Thomas

Jim Thomas is a writer based in Indiana. He holds a bachelor's degree in Political Science, a law degree from U.I.C. Law School, and has practiced law for more than 20 years.

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