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.”
A jury convicted Dugan, 67, on December 19 of the obstruction felony and acquitted her of a misdemeanor concealment charge. She resigned from the Milwaukee County Circuit Court two weeks later amid impeachment threats from Republican state lawmakers. She faces up to five years in prison, though federal guidelines typically recommend probation for first-time, nonviolent offenders.
Flores-Ruiz later pleaded guilty to illegal reentry and was deported on November 13, 2025. Dugan’s legal team described Tuesday’s ruling as “wrong.” The case is widely expected to reach the 7th U.S. Circuit Court of Appeals after sentencing.
The decision comes amid ongoing national debate over ICE enforcement actions inside courthouses and the scope of judicial authority when federal immigration agents are executing warrants. Adelman’s order focuses on the specific facts of this operation — the existence of an arrest warrant and the targeted nature of the enforcement — as key to distinguishing it from routine police encounters. The ruling is likely to influence how courts in the 7th Circuit interpret the obstruction statute in similar courthouse interference cases going forward.
Nearly 150,000 California Mail Ballots Rejected In Primary
California election officials are examining why nearly 150,000 mail-in ballots were rejected during the state’s June primary, with late-arriving ballots accounting for most of the increase.
The higher rejection rate comes despite years of election law changes designed to make voting more accessible and ensure more ballots are ultimately counted.
According to data compiled by the California Secretary of State’s office, 148,241 mail-in ballots were rejected during the June primary, representing 1.73% of all mail ballots returned.
That marks an increase from the 2024 primary, when 108,982 ballots were rejected, or 1.56% of all mail ballots cast.
The largest reason for rejection was ballots arriving too late to qualify under California law.
State data shows that 93,479 ballots were rejected because they failed to meet the state’s deadline requirements.
California allows mail ballots to arrive up to seven days after Election Day, provided they are postmarked on or before Election Day.
Voting experts believe many of the rejected ballots received postmarks dated after Election Day, making them ineligible to be counted even if they arrived within the seven-day grace period.
Kim Alexander, president of the nonpartisan California Voter Foundation, said the timing of postal processing appears to be a significant concern.
“Ballots rejected due to lateness are caused primarily to being postmarked too late to count, not because they arrived too late to count,” Alexander said.
Election experts have questioned whether recent operational changes within the U.S. Postal Service may be contributing to delayed postmarks.
Earlier this year, a group of mostly Democratic U.S. senators wrote to the Postal Service expressing concern that mail-processing changes could affect ballot handling during federal elections.
Updated Postal Service procedures mean postmarks may reflect when mail is processed at regional facilities rather than when it first enters the mail system.
Because processing centers have been consolidated in some areas, election officials have warned that postmark timing could be affected.
Before the June primary, California election officials encouraged voters to mail ballots as early as possible because of potential postal delays.
The June election also featured a highly competitive race for governor, which some experts believe encouraged many voters to wait until the final days before casting ballots.
In addition to late-arriving ballots, approximately 44,000 ballots were rejected because election officials determined the voter’s signature did not match the signature on file.
Another 8,300 ballots were rejected because the return envelope did not contain a signature.
State records also show that 743 ballots were rejected because those voters had already cast another ballot.
Other rejected ballots involved missing ballots inside return envelopes or multiple ballots submitted in a single envelope.
The highest rejection rate in the state occurred in Tulare County, where 3.52% of returned mail ballots were rejected.
Alpine County and Merced County followed closely, each recording rejection rates of 3.36%.
California has frequently faced criticism for taking weeks to complete vote counting after major elections, largely because state law permits ballots meeting certain requirements to continue arriving after Election Day.
Following the June primary, President Donald Trump again criticized California’s election system, while the Department of Justice opened an investigation into election administration in Los Angeles County.
Election experts emphasize that the increase in rejected ballots should not be interpreted as evidence of widespread voter fraud.
A 2025 report by the Brookings Institution found documented cases of mail ballot fraud remained extremely rare, estimating roughly four cases for every 10 million mail ballots cast, The Associated Press reported.
State officials have not identified evidence of widespread fraud connected to the June primary, but the increase in rejected ballots is expected to receive additional scrutiny as election administrators evaluate whether changes in postal operations, voter behavior or election procedures contributed to the higher rejection rate.
