Hannah Dugan | |
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| Judge of theMilwaukee CountyCircuit Court Branch 31 | |
| In office August 1, 2016 – January 3, 2026[a] | |
| Preceded by | Paul Rifelj |
| Personal details | |
| Born | Hannah C. Dugan 1959 (age 66–67) |
| Education | |
| Part ofa series on the |
| Immigration policy of the second Trump administration |
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Targeting of U.S. citizens |
Targeting of immigrants
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Controversies |
Hannah C. Dugan (born 1959)[1] is an American attorney who served as aWisconsin circuit court judge forMilwaukee County from 2016 until her resignation in 2026 after a jury found her guilty of a felony. Prior to her judicial service, Dugan was president of theMilwaukee Bar Association, served as an executive director ofCatholic Charities USA in southeastern Wisconsin, and worked with several legal aid organizations.
On April 25, 2025, Dugan was arrested by theFederal Bureau of Investigation andindicted on federal charges after she informed a defendant who was anillegal immigrant to the presence of federal immigration agents, directed him to leave through a nonpublic exit of the courthouse, and therebyimpeded federal agents who were attempting to take him into custody following a court appearance. The case drew national attention, with differing views expressed regarding the scope of federal enforcement authority and judicial conduct. Critics described the arrest as politically motivated and indicative of authoritarian enforcement under thesecond Trump administration, while supporters characterized it as a legitimate application of federal law.[2][3][4]
The Wisconsin Supreme Court suspended Dugan from judicial duties pending the outcome of the case.[5] On December 18, 2025, a federal jury found her guilty of one felony count of obstructing federal agents and not guilty on a lesser misdemeanor charge charge of concealing a wanted person.[6] Dugan resigned from the bench in a letter to Wisconsin governorTony Evers.[7] A sentencing date has not yet been set; according to U.S. media reports, Dugan faces up to five years in prison.[8]
Dugan holds a Bachelor of Arts degree in legal studies from theUniversity of Wisconsin, Madison, and a master's degree in American studies fromBoston College.[1] She graduated from theUniversity of Wisconsin Law School in 1987 and taught law courses atMarquette University and theSeattle University School of Law.[9] From 1999 to 2000, Dugan was president of theMilwaukee Bar Association.[10][11]
Dugan spent much of her career working withlegal aid organizations to provide assistance to people who are unable to afford legal representation,[11] and served as the executive director ofCatholic Charities of Southeastern Wisconsin from 2006 to 2009.[12] She was active in professional organizations and refereed attorney discipline cases brought by the Wisconsin Office of Lawyer Regulation.[13] Speaking to theMilwaukee Independent in 2016, Dugan stated that she found the judiciary situation in Milwaukee challenging, but believed in the independence of its judges.[13]
Dugan was elected a Wisconsin circuit court judge in2016, defeating incumbent Paul Rifelj with 65% of the vote.[14] During her tenure, she primarily oversaw cases in the court'smisdemeanor division.[11] Dugan was suspended by theWisconsin Supreme Court in April 2025 after being charged with the federal offenses related to allegedly helping an illegal immigrant evade arrest. She faced federal charges of concealing an individual to prevent his discovery and arrest and obstructing or impeding a proceeding.[15][16]
| Year | Election | Date | Elected | Defeated | Total | Plurality | ||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 2016 | General[17] | April 5 | Hannah C. Dugan | Nonpartisan | 132,461 | 64.90% | Paul Rifelj (inc) | Non. | 70,098 | 34.35% | 204,088 | 62,363 |
| 2022 | General[18] | April 5 | Hannah C. Dugan (inc) | Nonpartisan | 89,206 | 98.42% | —unopposed— | 90,640 | ||||
On April 18, 2025,US Immigration and Customs Enforcement (ICE) issued anarrest warrant for Eduardo Flores-Ruiz, a 30-year-old illegal immigrant from Mexico accused ofmisdemeanor battery, who was set to appear in court on April 18, 2025, before Dugan on charges of battery and domestic abuse.[19]
From 2019 to January 21, 2025, a federal policy existed for ICE to refrain from making routine arrests at courthouses. On February 21, 2025, an interim guidance[20] was issued by U.S. Immigration and Customs Enforcement (ICE) titled "Enforcement Actions in or Near Protected Areas." Under this interim guidance, ICE officers or agents may conduct civil immigration enforcement actions in or near courthouses when they have credible information that leads them to believe the targeted alien(s) is or will be present at a specific location, and where such action is not precluded by laws imposed by the jurisdiction in which the civil immigration enforcement action will take place. According to anaffidavit filed by an FBI agent in support of the criminal complaint against her, Dugan was described as angry when she learned that ICE agents were waiting outside her courtroom to arrest Flores-Ruiz. She then allegedly questioned the agents in the hallway and asked whether they had a judicial warrant. They informed her that they had an administrative warrant[b] to detain Flores-Ruiz.[22][3] Dugan told the agents that they needed a judicial warrant, not an administrative warrant, and she directed them to speak to Chief Judge Carl Ashley.[9] She then returned to her courtroom.
According to theMilwaukee Journal Sentinel, when Chief Milwaukee County Circuit Judge Carl Ashley notified Dugan of this warrant via email, Dugan responded saying "a warrant was not presented in the hallway on the sixth floor".[24] After Dugan returned to her courtroom, instead of holding the hearing, she directed Flores-Ruiz and his attorney to leave using the jury room exit to the public hallway.[25][26] This alternate exit led through a hallway before opening to the public area where she and the agents had spoken.[27] Flores-Ruiz entered an elevator into which an agent also entered. They rode to the main exit from the building and left the building. When Flores-Ruiz began to leave the scene,[28] the ICE agents chased after him and arrested him near the intersection of West State Street and Tenth Street,[29] and Flores-Ruiz was taken to the Dodge Detention Facility inJuneau, Wisconsin.[27]
The FBI subsequently opened an investigation into whether Dugan helped an immigrant avoid arrest.[24][30] Dugan was arrested by FBI agents on April 25, 2025, and charged with two felony counts of obstruction and concealing an individual,[27] and she was jailed. She was released on her own recognizance later that day.[31] FBI DirectorKash Patel announced the arrest in a social media post onX, stating that Dugan had "intentionally misdirected federal agents away from the subject to be arrested in her courthouse".[32] He deleted the post shortly thereafter, but subsequently restored the post. United States Attorney GeneralPam Bondi also spoke publicly in support of the arrest of Dugan.[33]
Republican lawmakers applauded the arrest. FormerWisconsin GovernorScott Walker called on Republican leaders of theWisconsin Legislature to convene an extraordinary session toimpeach and remove Dugan from office.[34] United States Attorney GeneralPam Bondi stated that judiciary members obstructing immigration enforcement would face prosecution: "If you are harboring a fugitive, we don't care who you are. ... We will come after you and we will prosecute you."[35][33]
Dugan's arrest was condemned byDemocratic lawmakers.[36] U.S. SenatorTammy Baldwin accused PresidentDonald Trump of attacking democratic values, saying that the arrest threatens to breach theseparation of powers.[37][33]Milwaukee MayorCavalier Johnson said that aggressive federal interference at theMilwaukee County Courthouse was having a detrimental effect on normal legal processes.[38]
TheMilwaukee Journal Sentinel reported that five legal experts, including former federal prosecutors, did not believe Dugan should be charged with a federal crime.[2] More than 150 former state and federal judges called Dugan's arrest an attempt to intimidate the courts.[39] Retired Massachusetts Supreme Court justiceGeraldine Hines commented that the prosecution was "an effort to intimidate judges".[4] Protests were held outside theU.S. Courthouse in Milwaukee on April 25 and theFBI field office inSt. Francis on April 26.[40][41]
Dugan was brought before U.S. Magistrate JudgeStephen C. Dries that morning forarraignment and she made no public comments, but her attorney told the court that Dugan "wholeheartedly regrets and protests her arrest. It was not made in the interest ofpublic safety."[27][42] Following her initial hearing, Dugan hired former U.S. AttorneySteven M. Biskupic and former U.S. Solicitor GeneralPaul Clement to represent her.[43][44]
Chief Judge Carl Ashley said in a statement that Dugan's caseload would be handled by another jurist in the courthouse and declined to comment further.[3] Areserve judge would be appointed to take over Dugan's caseload.[45] On April 29, 2025, theWisconsin Supreme Court issued an order relieving Dugan of her duties during the length of her federal trial.[46][47] On May 13, 2025, Dugan was indicted by afederal grand jury for concealing a person from arrest and obstruction of proceedings.[31] On November 7, 2025, prosecutors submitted evidence to the defense for the upcoming trial. Included in the latest filing was a reference to another judge who said she was uncomfortable when Judge Dugan brought her along to confront an arrest team waiting in the hallway for Eduardo Flores Ruiz.[48]
On May 14, Dugan's attorneys moved todismiss the case, on the basis ofjudicial immunity, official acts, and theTenth Amendment. They wrote, "The government's prosecution of Judge Dugan is virtually unprecedented and entirely unconstitutional".[49] To support their position they cited the 2024 U.S. Supreme court decisionTrump v. United States. They asserted that the decision provides immunity to Judge Dugan for all official acts within her exclusive constitutional authority. These official acts include directing someone where to go within her courtroom.[50]
On May 30, 138 retired state and federal judges filed anamicus brief, stating that Dugan "is entitled to absolute immunity for her official acts", and that the court should dismiss the charges against her. They characterized the prosecution as an "egregious overreach by the executive branch" that "would create a chilling effect on judges" if allowed to proceed, and that "threatens public trust in the judicial system and the ability of the public to avail themselves of courthouses without fear of reprisal".[51][52] On August 26, JudgeLynn Adelman declined to dismiss the charges, and trial was set for December 15.[53] Flores-Ruiz was deported in November 2025 after pleading no contest to the battery charge and being sentenced to time served.[54]
Dugan's trial began on December 15, 2025, in federal court in Milwaukee before JudgeLynn Adelman.[54] In opening statements, Assistant U.S. Attorney Keith Alexander told jurors that Dugan said she would "take the heat" for directing Flores-Ruiz through a private courtroom door while federal agents were waiting to arrest him.[55]
Defense attorneySteven M. Biskupic argued that Dugan had no intention of obstructing agents and was following courthouse policy when she directed them to speak with Chief Judge Carl Ashley. He noted that other agents still in the hallway chose not to arrest Flores-Ruiz when he emerged through the door, instead following him outside the building, stating, "Now, after the fact, everyone wants to blame Judge Dugan."[55]
The government's case was expected to include testimony from approximately two dozen witnesses.[54] The first witness was FBI agent Erin Lucker, who explained video footage showing the courthouse's back corridors.[55] On December 18, Dugan was found guilty of a felony count of obstructing federal agents and not guilty on a lesser misdemeanor charge of concealing a wanted person.[6]
On January 3, 2026, Dugan resigned as a Milwaukee County Circuit Court judge in a letter to Governor Tony Evers. In the letter, she said the federal case against her was ongoing and argued it raised concerns about judicial independence, but said Milwaukee County "deserve[s] to start the year with a judge on the bench" rather than have the court’s leadership become part of a partisan fight in the legislature.[56] Evers' office said he would move to fill the vacancy without delay. Republican Assembly Speaker Robin Vos praised the resignation, which came after Republican lawmakers had threatened impeachment following her conviction.[7]
Media related toHannah Dugan at Wikimedia Commons