Federal Judge Won’t Vacate Dugan Conviction

Milwaukee Federal Courthouse. Photo by Mariiana Tzotcheva

U.S. District Court Judge Lynn Adelman issued a decision Monday denying a motion to vacate the federal criminal conviction against former Milwaukee County Circuit Court Judge Hannah Dugan.

Dugan was convicted on one count of felony obstruction in 2025 following an incident at the Milwaukee County Courthouse. Federal agents went to the courthouse that day to arrest Eduardo Flores-Ruiz, an undocumented immigrant appearing in Dugan’s courtroom on criminal charges. She sent Flores-Ruiz out a side door of her courtroom after learning federal immigration agents were in the hallway. The government alleged she was trying to help him evade arrest.

During a four-day trial, federal prosecutors argued that Dugan knowingly obstructed the arrest and tried to conceal Flores-Ruiz. Her defense argued Dugan was acting under widespread confusion and uncertainty in the courthouse about how to handle Immigration and Customs Enforcement (ICE) agents in the wake of previous arrests that shocked courthouse personnel and the wider community. On Dec. 18, after a four-day trial, a jury found Dugan guilty on one count of obstruction of a federal deportation proceeding and not guilty on one count of concealing an individual from arrest.

After the conviction, Dugan’s legal team filed motions asking Adelman to vacate the conviction and seeking a new trial. They argued  ICE did not have a legal right to make an arrest in the courthouse that day, and that she should not have been convicted on the charge of obstruction because she didn’t know the agents were there to arrest Flores-Ruiz.

During jury deliberations, jurors asked Adelman whether Dugan needed to know the identity of the person ICE was after to be guilty of the charge. Dugan argued the judge’s instructions were incorrect regarding the charge she was convicted on.

In his order, Adelman rejected both arguments, as well as previous arguments made prior to the trial that Dugan was immune from criminal arrest for official judicial actions.

“Dugan has still not been sentenced for the offense and can still appeal the decision to a higher court, which would be the 7th Circuit Court of Appeals… No court policy forbade civil ICE arrests in public areas of the Milwaukee County Courthouse or otherwise sanctioned defendant’s course of conduct on April 18, 2025,” Adelman wrote, addressing arguments about the legality of the arrest.

While responding to Dugan’s arguments about his jury instructions on the second count, Adelman said Dugan was failing to address the “instructions as a whole” he provided. “In any event,” Adelman concluded, “defendant fails to show that my response to the jury’s second question was wrong.”

Adelman’s ruling upholds the conviction against her. Dugan can still appeal the decision and her lawyers seem likely to do so.

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