Balanced
Apr 19, 2026

Former Judge's ICE Obstruction Conviction Upheld

MILWAUKEE, Wis. — June 18, 2026

A federal judge in Milwaukee denied former Wisconsin Circuit Judge Hannah Dugan’s motion for reconsideration Tuesday, upholding her felony obstruction conviction and clearing the way for sentencing in a case that drew national attention as an early flashpoint in the Trump administration’s courthouse immigration enforcement efforts.

 

 

 

 

U.S. District Judge Lynn Adelman, appointed by former President Bill Clinton, issued a 32-page order ruling that Dugan’s conduct on April 18, 2025, obstructed a “pending proceeding” within the meaning of 18 U.S.C. Section 1505. On that date, Dugan led Eduardo Flores-Ruiz, a Mexican national, out a private jury door while federal immigration agents waited in the corridor.

 

 

Dugan’s lawyers had pressed Adelman to reconsider after the 4th U.S. Circuit Court of Appeals split 2-1 in April in United States v. Hernandez, holding that ICE’s execution of an already-issued removal order did not count as a “pending proceeding” under the statute.

 

 

 

Adelman drew a sharp factual distinction. In this case, she wrote, 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 wrote. “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.”

 

 

 

 

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