The Seventh Circuit Court of Appeals affirmed a district court's summary judgment ruling dismissing a Title VII hostile work environment claim brought by a former Cook County probation officer who alleged racial discrimination led to her termination.

In *Tonnette Jones v. Avik Das*, decided Jan. 22, 2026, the three-judge panel unanimously upheld the U.S. District Court for the Northern District of Illinois's decision to grant summary judgment in favor of Cook County's Juvenile Probation Department and its officials.

Tonnette Jones, who is African American, worked as a juvenile probation officer with Cook County's Juvenile Probation Department from February 2015 to March 2018. Her primary responsibilities included conducting social investigations and preparing written reports for the court to aid in sentencing decisions. Department policy required supervisors to review and approve all draft reports before submission to the court.

The Department terminated Jones in early 2018, citing performance issues and insubordination as the reasons for her dismissal. However, Jones alleged that her supervisors created a hostile work environment based on her race, violating federal employment discrimination laws.

Following her termination, Jones first challenged the decision through her union via the arbitration process available under her collective bargaining agreement. When that effort proved unsuccessful, Jones filed suit in federal court under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination based on race, color, religion, sex, or national origin.

Jones's federal lawsuit, filed as case number 1:18-cv-01319, alleged that her employer created hostile conditions of employment that violated Title VII's prohibition against racial discrimination. The case was assigned to District Judge Mary M. Rowland in the Northern District of Illinois, Eastern Division.

The district court granted summary judgment in favor of Cook County and the individual defendants, effectively dismissing Jones's hostile work environment claim before trial. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.

Jones appealed the district court's ruling to the Seventh Circuit, which heard oral arguments in the case on Sept. 9, 2025. The case was heard by a panel consisting of Circuit Judges Diane St. Eve, Doris L. Lee, and Joshua P. Kolar.

Writing for the unanimous panel, Circuit Judge Kolar applied the standard legal framework for reviewing summary judgment decisions. Under established precedent, appellate courts must view all facts and draw all inferences in the light most favorable to the non-moving party—in this case, Jones. This standard, established in *Anderson v. Liberty Lobby, Inc.* (1986), ensures that summary judgment is only granted when no reasonable jury could find in favor of the plaintiff.

Despite applying this plaintiff-friendly standard of review, the Seventh Circuit concluded that the district court correctly granted summary judgment in favor of Cook County. The appeals court's decision suggests that Jones failed to present sufficient evidence to support her Title VII hostile work environment claim, even when viewing the evidence in the light most favorable to her position.

Title VII hostile work environment claims require plaintiffs to demonstrate that they were subjected to unwelcome harassment based on their protected characteristics, that the harassment was sufficiently severe or pervasive to alter the conditions of employment, and that the employer knew or should have known about the harassment but failed to take appropriate remedial action.

The timing of Jones's case reflects the complex procedural requirements that often govern employment discrimination disputes. Her initial recourse through union arbitration, followed by federal litigation, illustrates the multiple forums available to public employees seeking to challenge adverse employment actions.

The case also highlights the challenges faced by employment discrimination plaintiffs in federal court. Summary judgment motions are common in Title VII cases, as employers frequently argue that plaintiffs cannot establish the necessary elements of their discrimination claims without proceeding to trial.

For Cook County, the Seventh Circuit's affirmance represents a complete victory in defending against Jones's discrimination allegations. The ruling validates the county's position that Jones's termination was based on legitimate, non-discriminatory reasons rather than racial bias.

The decision adds to the body of Seventh Circuit precedent interpreting Title VII's hostile work environment standards in the context of public employment. While the published portion of the opinion does not detail the specific incidents that formed the basis of Jones's claims, the court's affirmance suggests that whatever conduct Jones alleged was insufficient to meet federal standards for actionable workplace harassment.

Jones's case underscores the high evidentiary bar that employment discrimination plaintiffs must clear to survive summary judgment in federal court. The Seventh Circuit's unanimous affirmance indicates that the appeals court found the district court's legal analysis sound and its factual conclusions well-supported by the record.

The ruling is final unless Jones seeks further review from the Supreme Court, though the high court accepts only a small percentage of petitions for certiorari. For now, the Seventh Circuit's decision stands as the final word on Jones's discrimination claims against Cook County's Juvenile Probation Department.