Former Milwaukee County Circuit Judge Hannah Dugan was denied her last-ditch effort to toss her conviction on obstruction charges for helping an illegal immigrant evade arrest Tuesday.
U.S. District Judge Lynn Adelman, an appointee of former President Bill Clinton, denied Dugan’s motion, finding that she was unable to “satisfy the burden required for reconsideration” of a jury’s December decision convicting her of obstruction. Dugan was convicted by a federal jury for obstructing a pending proceeding when she helped Eduardo Flores-Ruiz, an illegal immigrant who appeared in April 2025 before her court, and his lawyer exit her courtroom via a side door after federal immigration officers appeared at the courthouse to arrest him.
Dugan’s argument for why Adelman should toss the conviction relied on a ruling by the U.S. Court of Appeals for the Fourth Circuit finding an immigration arrest was not “pending proceeding,” in a case about an illegal immigrant being detained by federal immigration officers, who later escaped and was rearrested by federal officers. Adelman explained in his Tuesday ruling that the appeals court ruling Dugan tried to use to justify tossing out her conviction involved a “different factual context” and does not provide “persuasive justification for excluding the ICE proceeding at issue in this case” from the definition of a “pending proceeding.”
“The problem for the defense is that this case did not involve some random encounter on the street. It was a targeted operation, conducted pursuant to agency procedures, including the issuance of an arrest warrant for a specific person, Eduardo Flores-Ruiz,” Adelman wrote in his ruling.
“After the arrest of Flores-Ruiz, ICE followed its procedures for reinstatement of the previous order of removal, determining that he should be removed from the country,” he said. “While this did not involve a contested hearing in front of an immigration judge or other authority, that is because Flores-Ruiz declined to challenge the previous order or make a claim for asylum.”
The former state judge had been set to be sentenced on June 3 but that hearing was postponed by Adelman pending the resolution of the motion to toss out the conviction. With Adelman denying Dugan’s motion Tuesday, sentencing will likely be rescheduled in the coming weeks.
FORMER JUDGE HANNAH DUGAN URGES COURT TO TOSS CONVICTION IN ILLEGAL IMMIGRANT ESCAPE CASE
Dugan’s conviction carries a maximum penalty of five years in prison, but because she has no prior criminal record, she is unlikely to get close to the maximum sentence. Her lawyers have said they plan to appeal the conviction to the U.S. Court of Appeals for the Seventh Circuit.
The ruling by Adelman is a significant win for the Department of Justice, which had paraded Dugan’s April 2025 arrest and later conviction as a high-profile example that “no one is above the law,” as FBI Director Kash Patel asserted in a post at the time of her arrest.