MADISON, Wis. — A federal judge on Tuesday declined to overturn a Wisconsin judge’s obstruction of justice conviction for helping a man evade immigration officers who showed up at a courtroom looking to detain him.
The case against Hannah Dugan, who resigned from the Milwaukee County Circuit Court following her conviction, was an early test of how the courts would respond to President Donald Trump’s sweeping immigration crackdown.
Trump allies branded Dugan as an activist judge, while her supporters said she was unfairly targeted.
U.S. District Judge Lynn Adelman postponed Dugan’s sentencing on June 3 to consider arguments about whether he should overturn her conviction. But Adelman said in his ruling Tuesday that Dugan’s conviction would stand. He did not immediately set a sentencing date.
“The court’s decision is wrong,” Dugan’s legal defense team said in a statement.
Questions about a similar case in Virginia
Dugan’s attorney had argued that her conviction in helping Eduardo Flores-Ruiz leave the courthouse was invalid and should be overturned. He said that was necessary because a federal appeals court in April overturned a key Virginia immigration case that the judge and prosecutors had cited in Dugan’s case.
In the Virginia case, an immigrant who was in the country illegally was detained by U.S. Immigration and Customs Enforcement agents and later escaped. He was recaptured and indicted on a charge of obstructing a pending immigration proceeding.
The federal appeals court found that the ICE action did not constitute a “pending proceeding,” as is required under the federal obstruction law.
Dugan’s attorneys argue that she should not have been charged because there was no “pending proceeding” against the immigrant in her courtroom being sought by ICE agents, only a warrant filed for his arrest. The filing of a warrant does not constitute a “proceeding” under the law, Dugan’s attorneys argued.
Prosecutors countered that the facts in the Virginia case are different and don’t apply to Dugan’s. They also argued that other cases support Dugan’s conviction.
Adelman said the attempted arrest of Flores-Ruiz did count as a “pending proceeding,” in part because it was a planned and targeted operation rather than an arrest resulting from a random encounter.
“Defendant argues that ICE was acting as a law enforcement agency here,” Adelman wrote. “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 faces 5 years in prison, but will likely get probation
Dugan, 67, faces up to five years in prison after a jury convicted her on Dec. 19, but she is unlikely to be sentenced to time behind bars. Federal sentencing guidelines generally call for probation for defendants like her, who have no criminal history and are convicted of a nonviolent crime.
Dugan resigned from her position as a Milwaukee County circuit judge two weeks after her conviction amid threats of impeachment from Republican state lawmakers. She had been a judge for nine years.
The Trump administration brought the case against Dugan as the president pressed ahead with his sweeping immigration crackdown. Trump’s administration and his allies branded Dugan as an activist judge, while Dugan’s attorneys said she was being unfairly targeted and argued, unsuccessfully, that she was immune from being charged because she was a judge.
Dugan’s case marked the first time that a state judge in Wisconsin went to trial on charges of obstructing immigration agents. She was acquitted of concealing an individual to prevent arrest, a misdemeanor.
Dugan helped an immigrant wanted by ICE agents
On April 18, 2025, immigration officers went to the Milwaukee County courthouse after learning Flores-Ruiz had reentered the country illegally and was scheduled to appear before Dugan for a hearing in a state battery case.
Dugan confronted agents outside her courtroom and directed them to the chief judge’s office because she told them their administrative warrant wasn’t sufficient grounds to arrest Flores-Ruiz.
After the agents left, she led Flores-Ruiz and his attorney out a private jury door. Agents spotted Flores-Ruiz in the corridor, followed him outside and arrested him after a foot chase. A week later, FBI agents arrested Dugan in the courthouse, leading her outside in handcuffs.
Flores-Ruiz was deported in November.
