Here's What Former Judge Hannah Dugan Tried to Argue to Get Her Obstruction Conviction Reconsidered

Amy mentioned this yesterday, but let’s revisit the simple lesson here about Hannah Dugan, the former Wisconsin judge who blocked an ICE operation by escorting an illegal immigrant out a nonpublic exit after she discovered federal agents were there to arrest him in April 2025. Eduardo Flores-Ruiz, 30, was in her courtroom on a domestic battery case. Dugan was arrested and charged with obstruction and was later found guilty.

She attempted to persuade the court to reconsider, even to grant her a new trial. Both motions were denied by Judge Lynn Adelman, who, by all accounts, is not a conservative. Here’s what Duggan tried to argue in her hail-mary motion (via WISN 12 ABC):

Can a state court judge help an illegal immigrant escape law enforcement? No, that's a crime. Judge Dugan of Wisconsin moved to recondider her conviction. Judge Adelman (no conservative jurist) denies the motion. Good opinion explaining why, in part persuaded by Judge Wilkinson pic.twitter.com/jWMHjMsQAk

— Eric W. (@EWess92) June 16, 2026

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.

Here’s the lesson, Hannah: no one is above the law.