A federal court in Milwaukee has upheld the first-of-its-kind conviction for a state judge who tried to help a migrant evade federal officers.
Former Milwaukee County Judge Hannah Dugan’s arguments seeking to overturn her felony obstruction conviction were rejected Monday by US District Court for the Eastern District of Wisconsin Judge Lynn Adelman.
Adelman gave Dugan’s legal team extra time to build their case that she was immune from prosecution, that her actions in her courtroom last spring couldn’t be considered “corrupt,” and that the federal obstruction statute didn’t fit these circumstances. In the end, the former Democratic lawmaker-turned-federal jurist rebuffed every claim.
“As I had noted in denying defendant’s motion to dismiss, there was no basis for granting immunity simply because some of the allegations in the indictment describe conduct that could be considered part of a judge’s job,” he said.
The 39-page decision goes through Dugan’s actions in and out of her chambers, from confronting officers who wanted to arrest a migrant appearing before her on domestic violence charges, to admitting to staff in her chambers that ushering him toward a private hallway away from his pursuers could land her in trouble. While the jury convicted her on felony obstruction, it acquitted her on a charge for unlawfully concealing a migrant.
“We continue to maintain that Hannah Dugan acted lawfully and within her independent authority as a judge,” her legal team said in a statement. “The inconsistent jury verdicts demonstrate that the trial proceedings were flawed, and we plan to appeal.”
The ruling rebuffed Dugan’s arguments that her actions didn’t have a close connection to the migrant’s deportation proceedings, and that the conviction was improper because immigration officers didn’t have legal authority to make their arrest in the courthouse. Even if migrants could potentially levy some argument against federal actions in state courts, she couldn’t invoke that as a privilege defense Adelman said.
Further, Dugan’s comments that she would “take the heat” and that she was “in the doghouse” with her chief judge over her actions demonstrated her knowledge of her culpability, Adelman added.
Even if Dugan “had not waived the argument, and even if the district court cases defendant cites are right and” other precedent against her “is wrong regarding the applicability of the privilege to civil ICE arrests in courthouses (an issue I need not decide), defendant cites no authority that she may assert the privilege in this context,” Adelman said.
The Justice Department represents the government. The US Attorney’s Office for the Eastern District of Wisconsin declined to comment.
Dugan is represented by Strang Bradley LLC, Gimbel Reilly Guerin & Brown LLP, and Steven Biskupic of Thiensville, Wis.
The case is United States v. Dugan, E.D. Wis., No. 2:25-cr-00089, 4/6/26.
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