A federal judge refused Tuesday to overturn the felony conviction of former Milwaukee County Circuit Court Judge Hannah Dugan, who obstructed ICE agents attempting to detain an illegal immigrant outside her courtroom in 2025. The decision exhausts Dugan’s immediate options for avoiding prison time after a jury found her guilty of obstruction in December.
Dugan faces up to five years in federal prison. She blocked Immigration and Customs Enforcement officers from taking custody of a defendant in the hallway outside her courtroom, then claimed judicial immunity protected her actions.
Judge Rejected Immunity Defense Twice
U.S. District Judge Lynn Adelman, a Clinton appointee, denied Dugan’s second motion for a new trial following oral arguments Wednesday. Her attorney, Steven Biskupic, argued that a recent Fourth Circuit ruling narrowing the definition of “pending proceeding” should apply to Dugan’s case and require reversal.
Adelman disagreed. The jury had acquitted Dugan on a lesser charge of concealing someone facing deportation but convicted on the more serious obstruction count after a week-long trial before Christmas.
Dugan first asked for a new trial immediately after her conviction, claiming immunity for “acts done within her purview as a judge controlling her courtroom.” Adelman rejected that argument but noted he might reconsider if an appeal in United States v. Hernandez came down differently. When that Fourth Circuit decision arrived in April, Dugan tried again. Adelman rejected her a second time.
What Happens to Convicted Judges
The case puts Dugan in the rare category of sitting judges convicted of felonies while in office. She left the bench after her indictment in May 2025.
Federal prosecutors argued throughout that no judge has authority to interfere with lawful immigration enforcement, regardless of where it occurs. The jury agreed ICE was conducting a legitimate operation when Dugan stepped in.
Dugan can still appeal to the Seventh Circuit Court of Appeals, but with Adelman twice rejecting her core legal arguments, her path to reversal has narrowed considerably. Sentencing has not yet been scheduled.
Key Points
- Former Milwaukee judge Hannah Dugan convicted of obstructing ICE agents outside her courtroom faces up to five years in prison
- Federal judge rejected her immunity defense for the second time, exhausting immediate appeal options
- Dugan physically interfered with lawful immigration enforcement, then claimed judges have authority to block federal agents in courthouse hallways
https://www.courthousenews.com/former-milwaukee-judge-loses-last-chance-appeal-of-ice-obstruction-conviction/ – June 16, 2026
