Federal judge pauses sentencing over immigration obstruction case

sentencing postponed – A federal judge postponed sentencing for former Wisconsin Judge Hannah Dugan indefinitely to consider whether a prior jury guilty verdict for felony obstruction should be overturned, after arguments hinged on an appeals court decision in a Virginia immigration

MILWAUKEE — The sentencing that was supposed to begin Wednesday never started.

Instead, U.S. District Judge Lynn Adelman postponed the proceedings indefinitely, stepping away from a verdict that already had a jury behind it. Adelman did not announce a ruling from the bench and did not say when he might decide. leaving Hannah Dugan and attorneys for both sides to leave the courtroom without commenting to reporters.

The pause puts fresh weight on a legal question that has become an early test of how federal courts may respond to President Donald Trump’s immigration crackdown. Dugan was scheduled for sentencing after a jury convicted her of felony obstruction for helping an immigrant evade federal officers.

Dugan’s attorney argued the conviction rests on a theory that can’t survive after a key change

Dugan’s attorney, Steven Biskupic, asked the court to throw out the guilty verdict. His argument focused on timing and procedure: he said Dugan’s conviction was invalid and should be overturned because a federal appeals court in April overturned a key Virginia immigration case that the judge and prosecutors in Dugan’s case had relied on.

“Our primary argument is this was an invalid theory of conviction,” Biskupic said.

In the Virginia case, an immigrant who was in the country illegally was detained by U.S. Immigration and Customs Enforcement agents and later escaped. He was recaptured and indicted on a charge of obstructing a pending immigration proceeding.

The federal appeals court ruled that the ICE action did not constitute a “pending proceeding,” as the federal obstruction law requires.

Biskupic argued Dugan’s situation doesn’t meet that same standard. Dugan’s attorneys said she should not have been charged because. in her courtroom. there was no “pending proceeding” against the immigrant that ICE agents were seeking—only a warrant for his arrest. Under that view, the filing of a warrant does not count as a “proceeding” under the law.

Prosecutors pushed back, saying the facts differ and other cases support the conviction

Richard Frohling, the acting U.S. attorney for the eastern district of Wisconsin, countered that the Virginia facts were different and did not apply to Dugan’s case. He also argued other cases supported the conviction.

“The court should stick with its ruling,” Frohling said.

When the judge pressed him with questions, Frohling argued that the appeals court’s decision overturning the Virginia case was wrong. He also told the court that what constitutes a proceeding—and how long it lasts—depends on context.

“It could be a couple minutes, it could be a couple years,” Frohling said. “It all depends on the context.”

Sentencing paused after Dec. 19 conviction; guidelines suggest probation despite felony exposure

Dugan, 67, faces up to five years in prison after the jury convicted her on Dec. 19. Still, federal sentencing guidelines generally call for probation for defendants like her who have no criminal history and are convicted of a nonviolent crime.

Dugan resigned as a Milwaukee County circuit judge two weeks after her conviction. The resignation came amid threats of impeachment from Republican state lawmakers. She had been a judge for nine years. Dugan was present for Wednesday’s arguments but did not speak.

The case, brought by the Trump administration, came as the president pressed ahead with sweeping immigration enforcement. The Trump administration and allies branded Dugan as an activist judge. Dugan’s attorneys argued she was being unfairly targeted and had unsuccessfully argued she was immune from being charged because she was a judge.

This was the first time a state judge in Wisconsin went to trial on charges of obstructing immigration agents. Alongside the conviction, the jury acquitted her of concealing an individual to prevent arrest, a misdemeanor.

What happened at the Milwaukee County courthouse began with a state hearing and ended with a foot chase

The case centers on what Dugan did when immigration officers came to her courthouse.

On April 18, 2025, immigration officers went to the Milwaukee County courthouse after learning Eduardo Flores-Ruiz had reentered the country illegally and was scheduled to appear before Dugan for a hearing in a state battery case.

Dugan confronted agents outside her courtroom and directed them to the chief judge’s office because she told them their administrative warrant wasn’t sufficient grounds to arrest Flores-Ruiz. After the agents left, she led Flores-Ruiz and his attorney out a private jury door.

Agents spotted Flores-Ruiz in the corridor, followed him outside, and arrested him after a foot chase. A week later, FBI agents arrested Dugan in the courthouse, leading her outside in handcuffs.

Flores-Ruiz was deported in November.

Hannah Dugan Lynn Adelman felony obstruction immigration crackdown Wisconsin judge Milwaukee County Eduardo Flores-Ruiz ICE sentencing postponed Trump administration