A federal judge just slammed the door on a disgraced former state judge’s latest attempt to escape a felony conviction for obstructing federal immigration agents in his own courtroom.
Story Overview
- Former Milwaukee County Judge Hannah Dugan lost her bid for a new trial after she was convicted of obstruction for obstructing ICE agents who were trying to arrest her in her courtroom.
- Federal Judge Lynn Adelman issued a 39-page ruling on April 6, 2026, rejecting Dugan’s claims of judicial immunity, stating that there is no blanket criminal immunity for judges.
- Dugan faces up to five years in prison and has already resigned from the bench following his conviction in December 2025.
- The case highlights escalating tensions between the state judiciary and federal immigration authorities, with advocates warning of executive overreach while prosecutors defend the rule of law.
When a judge becomes a defendant
Hannah Dugan sat on the Milwaukee County bench, wielding the power to decide the fate of others. Then the spring of 2025 arrived and ICE agents entered his courtroom to arrest a defendant during proceedings. What happened next turned the referee into a defendant. Prosecutors alleged that Dugan directed the individual to his apartments and physically prevented federal agents from carrying out their legal duty. On December 18, 2025, a federal jury convicted her of felony obstruction, although it acquitted her of a related misdemeanor receiving stolen property charge. The maximum sentence is five years in federal prison.
The failed immune defense
Dugan’s legal team took the stand with her post-trial motion, arguing that legal immunity should protect her from criminal prosecution for actions taken in her official capacity. After all, they thought, wasn’t she just exercising control over her courtroom? Federal Judge Lynn Adelman saw things differently. Its 39-page decision, delivered on April 6, 2026, methodically dismantled the immunity argument. Adelman wrote clearly: There is no general rule of criminal immunity for judges, even for conduct that could be considered part of their job. The decision reviewed existing case law and found no precedent supporting Dugan’s position.
The defense argument reveals a fundamental misunderstanding between judicial authority and federal law. Judges enjoy immunity from civil suits for their official actions, protecting them from frivolous litigation that could paralyze their decision-making. Criminal immunity is a whole different animal. If judges could claim immunity from criminal prosecution for obstructing federal officers, courthouse doors would become sanctuaries where federal law enforcement would lose its authority. This is not about judicial independence; it is judicial supremacy over federal law, a concept fundamentally at odds with our constitutional structure.
Federal authority versus courtroom control
The collision between ICE law enforcement and state courts has sparked a nationwide debate. Immigration advocates argue that federal agents entering courthouses during proceedings compromise public safety by dissuading immigrants from seeking justice or serving as witnesses. Dugan’s supporters, including the Democracy Defenders Fund led by Ambassador Norm Eisen, portrayed the prosecutions as executive overreach that threatens judicial independence. Eisen predicted the appeals would raise important constitutional questions about protecting the judiciary from federal interference. Yet this framework obscures a crucial distinction: federal agents did not intervene in legal proceedings; they were executing a legal arrest warrant.
ICE agents did not intervene to disrupt a trial or vacate a court order. They arrived to arrest an individual for whom they had valid federal authority. Dugan’s alleged response, moving the person away from agents and blocking their access, shifted from managing courtroom decorum to actively obstructing federal agents. The jury heard the testimony and distinguished between a judge who maintains order and a judge who prevents lawful execution. Six hours of deliberations resulted in a conviction that reflected the strength of the government’s arguments, not the excessive will of the executive.
The price of resistance
Dugan resigned from the bench in early 2026, his judicial career effectively over. The Democracy Defenders Fund highlighted Dugan’s financial burden, but did not provide specific figures. She now faces jail time and the certainty of an appeal, a process that promises years of legal wrangling and mounting costs. His supporters predict the case will move through appeals courts, potentially setting a precedent for immigration enforcement in courthouses. Milwaukee’s legal community watches nervously, unsure how the conviction might chill interactions between state judges and federal authorities.
The broader implications extend beyond the fate of a former judge. If appeals courts uphold Adelman’s decision, the message will resonate clearly: State judges cannot obstruct the enforcement of federal law, regardless of personal objections to immigration policy. Conversely, a reversal could encourage judges to actively resist ICE operations in courthouses, thereby escalating the conflict between federal law enforcement and local judicial autonomy. Immigrant communities face their own reckoning, balancing concerns about courthouse security against the precedent that even judges cannot protect individuals from federal arrest warrants.
When authority meets responsibility
The Dugan case raises an uncomfortable question about the limits of judicial power. Judges rightly command respect and deference in their courtrooms. This authority, however, arises from their role in administering justice under the law, not from personal sovereignty intended to override the application of federal law. Dugan’s conviction is a reminder that no public official, regardless of their position, acts above the law. Federal agents had the legal authority to make an arrest. A judge’s disagreement with immigration policy does not allow him or her to physically obstruct federal agents in the performance of their duties.
The conviction remains pending and the appeal appears certain. The constitutional questions raised by Eisen could eventually be taken to higher courts. Yet the basic facts remain undisputed: ICE agents attempted a lawful arrest, Dugan intervened, and a jury convicted her after hearing the evidence. Judge Adelman’s denial of her motion reinforces the fact that judicial robes confer neither criminal immunity nor the right to selectively enforce federal law. As Dugan’s case moves forward on appeal, it will shed light on whether U.S. courts truly operate under a single system of law or whether judges can carve out areas where federal authority cannot reach.
Sources:
Federal judge rejects Dugan’s request for new trial – WTMJ Milwaukee
Press release from the Fund for Democracy Defenders on the Dugan verdict
Former Milwaukee judge prepares for retrial – Courthouse News
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