U.S. District Judge Lynn Adelman on Tuesday rejected former Milwaukee County Circuit Judge Hannah Dugan’s latest motion seeking reconsideration of her felony conviction for obstructing federal immigration enforcement.
Adelman issued the ruling in the case against Dugan, 67, who was convicted by a jury in December 2025 of impeding a proceeding before the Department of Homeland Security. The jury acquitted her of a related misdemeanor count of concealing an individual to prevent his arrest.
The charges arose from an April 18, 2025, incident at the Milwaukee County Courthouse. Federal agents arrived with a warrant to arrest Eduardo Flores-Ruiz, who was in the country illegally following a prior deportation. Flores-Ruiz had a domestic battery case pending before Dugan.
Trial evidence showed agents notified Dugan of their intent. She directed Flores-Ruiz and his attorney out of her courtroom through a side door. Agents apprehended him outside the building. Flores-Ruiz was later deported.
Dugan’s attorneys had asked Adelman to reconsider his earlier denial of acquittal or a new trial, citing a Fourth Circuit decision in United States v. Hernandez. They argued it undermined the application of the obstruction statute to immigration enforcement actions. Adelman found the cases distinguishable.
In his order, Adelman noted that unlike Hernandez, where ICE was executing a final removal order, agents in Dugan’s case were still investigating Flores-Ruiz, securing a warrant and determining whether to reinstate his prior deportation. No final removal order existed at the time of the alleged obstruction, he wrote.
Adelman also rejected broader claims that ICE enforcement actions fall outside the obstruction statute, pointing to precedents from the Seventh and Ninth circuits involving other agencies. He said Dugan could not meet the high burden for reconsideration.
Dugan’s legal team said it plans to appeal.
“We continue to maintain that Hannah Dugan acted lawfully and within her independent authority as a judge,” her attorneys said in a statement. “The inconsistent jury verdicts demonstrate that the trial proceedings were flawed.”
Dugan resigned from the bench in January following her conviction. The Wisconsin Supreme Court had previously suspended her. Sentencing, previously delayed, is now expected to proceed. The felony count carries a maximum of five years in prison and a $350,000 fine.
Adelman’s latest ruling leaves Dugan’s conviction in place. The case is expected to head to the 7th U.S. Circuit Court of Appeals following sentencing.
