Former Wisconsin judge Hannah Dugan was convicted after she escorted an immigrant out of a courthouse to avoid an ICE arrest, then asked for a new trial based on a recent appeals court ruling; the motion was denied by Judge Lynn Adelman, who found the cases distinguishable and ruled that ICE’s ongoing enforcement actions can fall under the federal obstruction statute.
Hannah Dugan, once a judge in Wisconsin, drew national attention when she intervened in an ICE operation at a Milwaukee courthouse in April 2025. She escorted Eduardo Flores-Ruiz, 30, out of a nonpublic exit after learning federal agents were there to arrest him on immigration matters while he stood before the court for a domestic battery case. Dugan was arrested, charged with obstruction, tried, and found guilty by a jury.
After conviction she filed motions asking the court to reconsider the verdict and to grant a new trial, arguing recent appellate case law supported her position. Those motions landed before Judge Lynn Adelman, who reviewed the arguments and the legal differences between the cases Dugan cited and the facts at hand. Adelman denied both requests, rejecting the idea that the court must rewrite the obstruction statute’s reach in this situation.
Dugan leaned heavily on a Fourth Circuit decision, United States v. Hernandez, which held that an ICE attempt to carry out a deportation order did not qualify as a “pending proceeding” for purposes of the federal obstruction statute. Her team argued that precedent should shield her actions in Milwaukee because ICE was present to enforce immigration law. The court, however, noted key distinctions that made Hernandez a poor fit as a roadmap for reversing Dugan’s conviction.
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Judge Adelman emphasized that Hernandez involved a final order of removal and an ICE effort to put someone on a plane after they had been ordered deported. In the Milwaukee matter, by contrast, ICE was in the midst of its own investigative and enforcement process — seeking a warrant, assembling evidence, and making determinations about reinstatement of prior removal orders. Adelman concluded the situations were materially different at the moment Dugan acted.
Dugan was found guilty by a jury of obstructing ICE’s arrest of Eduardo Flores-Ruiz at a Milwaukee courthouse on April 18, 2025.
After trial, Dugan asked Adelman to reconsider based on a recent appeals court decision from Virginia. In that case, United States v. Hernandez, a divided panel of the Fourth Circuit ruled that ICE’s attempt to carry out a deportation order did not qualify as a “pending proceeding” under the federal obstruction statute.
Adelman said the two cases were different. In Hernandez, an immigration court had already ordered the defendant deported, and ICE was simply trying to put him on a plane when he escaped custody.
In Dugan’s case, ICE was still in the middle of its own process — investigating Flores-Ruiz, obtaining a warrant, and preparing to determine whether his earlier deportation order should be reinstated.
Unlike in Hernandez, at the time of the obstructive conduct in this case there was no final order of removal,” Adelman wrote.
The judge also rejected the broader argument that ICE enforcement actions can never be covered by the obstruction statute. He pointed to rulings from the Seventh and Ninth circuits holding that the SEC’s enforcement of securities laws and the IRS’s collection of tax debts both qualified as agency proceedings protected by the statute.
Adelman noted that ICE is different from agencies like the FBI because it can issue its own warrants and make its own removal decisions without going through a court, putting its work in a different category than routine police activity.
The judge also pushed back against a sweeping defense claim that all ICE enforcement is outside the obstruction statute’s scope. He cited other circuits where administrative enforcement activities were treated as protected agency proceedings under the law. By highlighting those rulings, the court undercut the claim that agency actions are inherently exempt from obstruction prosecutions.
Adelman pointed out that ICE, unlike some traditional police functions, has certain administrative authorities that allow it to pursue removal and issue warrants without routing everything through a separate judicial proceeding. That capacity places many ICE enforcement steps into a different legal category, one that courts have found can be covered by obstruction statutes in other contexts. The judge concluded the defendant’s conduct interfered with an ongoing agency process.
The case will likely remain a flashpoint in debates over immigration enforcement and courtroom conduct. Conservatives who emphasize rule of law will see the conviction and denial of reconsideration as a necessary stand against vigilante interference with federal enforcement. Those who favor broader protections for local actors confronting ICE will argue the case highlights tensions between community norms and federal authority.
What this episode ultimately underscores is a simple, blunt point about public office and the law: judges and court officials operate within legal limits. Actions to thwart federal enforcement inside a courthouse, no matter the motive, can meet the elements of obstruction when federal officers are engaged in an active enforcement process. Here’s the lesson, Hannah: no one is above the law.
