Federal Judge Upholds Hannah Dugan Obstruction Conviction In ICE Courthouse Case
On Wednesday, June 17, 2026, U.S. District Judge Lynn Adelman declined to overturn former Milwaukee County Judge Hannah Dugan's federal obstruction conviction in the ICE courthouse case, clearing the way for sentencing.[1]
Adelman ruled that Immigration and Customs Enforcement's planned April 18, 2025 arrest of Eduardo Flores-Ruiz at the Milwaukee courthouse qualified as a "pending proceeding" under the obstruction statute.[1] Dugan was convicted of felony obstruction on Dec. 19, 2025 and resigned from the Milwaukee County Circuit Court about two weeks later.[1] She faces up to five years in prison and is awaiting a new sentencing date.[1]
On April 18, 2025, ICE agents arrived at the Milwaukee County courthouse to arrest Flores-Ruiz on an immigration warrant after confirming a 2013 deportation and an unlawful return.[1] Prosecutors say Dugan routed agents away from her courtroom, escorted Flores-Ruiz through a private door, and agents later arrested him after a foot chase; he was deported in November 2025.[1]
Dugan's lawyers cited an April 2026 Fourth Circuit ruling in United States v. Hernandez that found an ICE enforcement action did not count as a "pending proceeding." PBS News Judge Adelman paused sentencing on June 3 while he considered that precedent.[1] Adelman's decision to deny the defense motion keeps the December felony conviction intact and clears the way for the court to set a sentencing date.[1]
The mainstream summary does not mention the broader context of ICE's operational changes that have led to increased courtroom arrests. In 2025, ICE not only increased arrests directly from courtrooms but also quadrupled its total interior arrests compared to previous years, driven by a significant rise in both jail transfers and street arrests. This shift in strategy highlights a growing federal emphasis on enforcement actions that directly target individuals in judicial settings, which critics argue undermines the integrity of the judicial process and raises concerns about due process rights.[2]
Furthermore, the summary overlooks the implications of the ruling in the context of sanctuary policies and judicial resistance to ICE operations. Many jurisdictions have adopted non-cooperation policies due to concerns about the impact of ICE arrests on community safety and family separations. This case exemplifies the tension between local judicial practices and federal immigration enforcement, as courts increasingly invoke common-law privileges to limit civil arrests in judicial facilities.[3]
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📊 Relevant Data
In 2025, ICE increased arrests directly from courtrooms nationwide as part of efforts to meet higher arrest targets, shifting from prior reliance primarily on jail transfers.
Number of 'no-shows' in immigration court rises nationwide — NPR
ICE quadrupled its total interior arrests in 2025 compared to the prior period, driven by both more jail transfers and an elevenfold rise in street arrests.
Immigration Enforcement in the First Nine Months of ... — Deportation Data Project
📌 Key Facts
- On June 17, 2026, Judge Lynn Adelman declined to overturn Hannah Dugan's federal obstruction conviction.
- Adelman ruled that ICE's April 18, 2025 planned arrest of Eduardo Flores-Ruiz at the Milwaukee courthouse was a "pending proceeding" under obstruction law.
- Dugan was convicted on Dec. 19, 2025, resigned from the Milwaukee County Circuit Court two weeks later, faces up to five years in prison and is awaiting a new sentencing date.
- Prosecutors say Dugan routed ICE agents away from her courtroom, then escorted Flores-Ruiz through a private door before agents arrested him after a foot chase; he was deported in November 2025.
📰 Source Timeline (1)
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