R | APPEAL | PETITION FOR A WRIT OF CERTIORARI (Makere v Allstate; §1981, 1985, EPA, FCRA, Title VII)

UNITED STATES SUPREME COURT

ELIAS MAKERE, FSA, MAAA
(Petitioner)

v.

ALLSTATE INSURANCE COMPANY
(Respondent)

On Petition for a Writ of Certiorari
to the
Eleventh Circuit Court of Appeals (US)

PETITION FOR WRIT OF CERTIORARI

Elias Makere, FSA, MAAA
Petitioner (“Civilian X”)
PO Box 324
Hobart, IN 46342
P: 904.294.0026
E: Justice.Actuarial@gmail.com
W: TextBookDiscrimination.com
Get Booked Up on Justice!

February 20, 2026

QUESTION PRESENTED

Q1	Is it unconstitutional for a State to obstruct someone’s access to a trial-by-jury (7th Amendment)?
Q2	Is it unconstitutional for a State to break the law (eg, perjury; evidence destruction) – then depart from Supreme Court precedent – in order to deny someone’s access to the courts (1st Amendment)?
Q3	Is it unconstitutional for a State statute to discriminate against civil rights litigants (14th Amendment)?

DISCLOSURES

UNITED STATES SUPREME COURT
Makere v Allstate, 24-____

LIST OF PARTIES
AND CORPORATE DISCLOSURE STATEMENT

Parties:
Allstate Insurance CompanyRespondent/Appellee/Defendant
Makere, EliasPetitioner/Appellant/Plaintiff

Petitioner is not a subsidiary/affiliate of a publicly owned corporation. Moreover, Petitioner is not a corporation (Rule 29.6 Sup. Ct. R.). Pursuant to Rule 26.1-2 11th Cir. R.,^1/ Petitioner does not know of any other entities that have interest in this case. Petitioner hereby certifies that this CIP is complete.

LIST OF PROCEEDINGS

Administrative Proceedings (State):

Makere v Allstate

Florida Commission on Human Relations
2017-01432; 2019-19238 | {12/15/2017; n/a}

Trial Court Proceedings (Federal):

Makere v Allstate

US District Court, Florida, Middle District
3:20-cv-000905 | {...8/9/2024}

Appellate Court Proceedings (Federal):

Makere v Allstate

Eleventh Circuit Court of Appeals (US)
24-11336-J | {...12/17/2025}

Supreme Court Proceedings (Federal):

Makere v Early

US Supreme Court
23-7081 | {4/29/2024}

----

with prejudice, a state broke the law – to cover-up a corporation's unlawful prejudices. then – with prejudice – the lower courts ratified the state’s (and the corporation’s) lawlessness. yet, those tribunals’ prejudicial acts/statutes blocked someone from proceeding [without prejudice]. thereby violating this Court’s holdings (as well as this Nation’s Constitution). so, may this higher Court preclude all states from preventing anyone from holding court with their corporations’ prejudices?

----

Questions Presented	C1
List of Parties	C2
Corporate Disclosure Statement	C2
List of Proceedings	C2

Prologue	i
Table of Contents	ii
Table of Authorities	ii
Jurisdictional Basis	iv
Statement of the Case	1
Argument in Support of Certiorari	4

Conclusion	8
Certificate of Compliance	-
Certificate of Service	-

TABLE OF AUTHORITIES

CASES

Bounds v Smith, 430 US 817 (1977)	6
Batson v Kentucky, 476 US 79 (1986)	4
Haines v Heggs, 658 So.2d 523 (Fla. 1995)	4
IRS v. Sunnen, 333 US 591 (1948)	4
McDonnell-Dougalas v Green, 411 US 792 (1973)	2, 5
Miami Herald v Tornillo, 418 US 241 (1974)	7
Minneapolis v Moquin, 283 US 520 (1931)	iv
Zipes v Trans World, 455 US 385 (1982)	iv

RULES

Local Rule 26.1-2 11th Cir. R.	C2
Local Rule 10(a) Sup. Ct. R.	4, 5, 7
Local Rule 29.1 Sup. Ct. R.	C2
Local Rule 30 Sup. Ct. R.	iv
Rule 5.1 Fed. R. Civ. P.	2
Rule 28(d) Fed. R. App. P.	iv

STATUTES (FEDERAL)

42 USC §1981	iv
42 USC §1983	iv, 2
42 USC §2000e	iv, 1

STATUTES (STATE)

§760 FS

iv, 1, 2, 6, 7

CONSTITUTIONS

1st Amendment (US)	iv, 3
11th Amendment (US)	iv, 3
14th Amendment (US)	iv, 3

ABBREVIATIONS

ALJ	Administrative Law Judge
LT	Lower Tribunal
FS	Florida Statutes
USCA11	US Circuit Court, Eleventh Circuit
USFLMD	US District Court, Florida, Middle District

JURISDICTIONAL BASIS

Introduction

Petitioner, Elias Makere, was the Appellant/Plaintiff in the lower tribunals; and will be referred to in this petition as “Employee X” (Rule 28(d) Fed. R. App. P.).^1/ Respondent, Allstate Insurance Company, was the Appellee/Defendant below; and will be referred to as “Company Y”.

Timeliness

This Petition is timely.

On December 17, 2025, USCA11 rendered its decision.^2/

Today (February 20, 2026) marks the 64^th day since that opinion (Rule 30 Sup. Ct. R.). Thus, by filing today, Employee X has met this Court’s time constraint (please accord electronic filing via the 11th Circuit – see Zipes v Trans World, 455 US 385 (1982)).

CONSTITUTIONAL PROVISIONS/STATUTES

• 1st Amendment of the US Constitution
• 7th Amendment of the US Constitution
• 14th Amendment of the US Constitution
• 42 USC §1981 (Equal Rights Under the Law)
• 42 USC §1983 (the Ku Klux Klan Act of 1871)
• 42 USC §2000e (The Federal Civil Rights Act)
• §760 FS (The Florida Civil Rights Act)

STATEMENT OF THE CASE

1. This is a civil rights case (under §760 FS; Title VII; etc.) between a man (ie, ’Employee X’) and a nationwide corporation (ie, ’Company Y’).

2. On June 30, 2017 – and pursuant to §760.11(1) FS – Employee X alleged that Company Y violated his civil rights on the bases of race and sex. The details of Company Y’s discrimination have included – but have not been limited to:

a. unwanted date requests;

b. racist dolls;

c. racist characterizations;

d. hostile work environments;

e. sabotaged work;

f. pay disparity (ie, Company Y paying Employee X a lower ASA salary than it paid its other similarly-situated employees);

g. denied work-from-home privileges;

h. registration-fee disparity (ie, Company Y forcing Employee X to pay for a $1,025 actuarial exam fee – while never doing the same to its other employees);

i. an illegitimate termination;

j. post-termination retaliation; and

k. much more.

3. To put it briefly: Employee X’s lawsuit against Company Y has presented a textbook case of employment discrimination.

a. Please accord McDonnell-Douglas v Green, 411 US 792 (1973) (“The Seminal Case”).

4. A textbook case which – unfortunately – runs counter to widespread propaganda (as foretold by the Ku Klux Klan itself; and its progenies). So, faced with these probative facts, the State of Florida went on the attack (violative of 42 USC §1983).

5. The gravest attack (perhaps) involved a state ALJ committing perjury (and destroying evidence). Thereby removing the sex discrimination charge from Employee X’s lawsuit (¶2 supra).

6. Yet, the most wide-ranging infidelity (regarding this petition) involved the unconstitutionality of the State of Florida’s administrative gauntlet. A gauntlet that featured (and always features) the State’s ability to hamper/prevent someone’s access-to-the-courts (ditto for trials-by-jury).

7. Of course, the State’s [unequally distributed] preclusions are borne out of state law (ie, §760 FS). Law, importantly, that is repugnant to the US Constitution (eg, state-sponsored bribery; unequal protections; etc.). Law, importantly, that Petitioner has [repeatedly] challenged – as being unconstitutional (Rule 5.1 Fed. R. Civ. P.).

Ultimate Facts

8. Company Y – in this textbook case of employment discrimination - is guilty of violating Employee X’s civil rights.

9. Plus, in its [pre-determined/prejudicial] quest to cover for Company Y, the State of Florida broke the law. Thereby further violating Employee X’s civil rights.

10. Importantly, the State of Florida has a statutorily prescribed method/practice of violating everyone’s constitutional rights (1st Amendment; 7th Amendment; 14th Amendment).

Procedural History

11. So, given the [aforementioned] harms/obstructions, Employee X filed suit in federal court. Doing so on-or-around August 12, 2020; and under various federal/state statutes.

12. On March 26, 2024, the District Court (ie, USFLMD) entered summary judgement in favor of Company Y; doing so on the basis of administrative timeliness. A decision, crucially, that was: (i) grounded on a [judicially noticed] falsehood; and (ii) on the heels of a state-sponsored onslaught of lawlessness.

13. On December 17, 2025, USCA11 affirmed the District Court’s decision.^2/ Thus, this Petition for a Writ of Certiorari ensued.

ARGUMENT IN SUPPORT OF A WRIT OF CERTIORARI

14. This Court is well-positioned to grant this writ, because this matter: (a) manifested an injustice; (b) conflicted with Supreme Court precedent; and (c) was repugnant to the US Constitution.

The Proceedings From Below Effectuated a Miscarriage of Justice

15. The LT proceedings suffered from severe lawlessness (eg, evidence destruction; judicial perjury; phantom determinations; etc.). Supreme Court precedent has long established that courts cannot base their decisions on lawlessness/falsehoods/frauds (IRS v Sunnen, 333 US 591 (1948); Minneapolis v Moquin, 283 US 520 (1931); Batson v Kentucky, 476 US 79 (1986)).

16. According to Florida’s supreme court, such lawlessness equates to a departure from the essential requirements of law:

“...in determining whether there was a ‘departure from the essential requirements of law’ reviewing courts have inquired: (1) whether the lower court proceeded ‘according to justice’ or deprived the petitioner of fundamental rights, resulting in serious and material injury or gross injustice...”

An important tenet that this Court has the power to act on (pursuant to Rule 10(a) Sup. Ct. R.).

17. Thus, Employee X hereby asks this Supreme Court to grant certiorari (due to miscarriages-of-justice – Q1/Q2). Especially considering the LTs’ second constitutional conflict.

The Lower Court Proceedings Defied Supreme Court Precedent

18. The LTs have contravened The Seminal Case. A contravention [of Supreme Court Precedent] which was highlighted by the State’s illegal conduct. Illegal conduct, notably, that centered around Florida’s [perjurous] removal of Employee X’s sex discrimination charge (¶5 supra).

19. A removal, of course, that this Court has [precisely/explicitly] disavowed (highlights added):

“[Employer] argues, as it did below, that [employee] sustained no prejudice from the trial court’s erroneous ruling, because, in fact, the [removed] issue of racial discrimination in the refusal to reemploy “was tried thoroughly...”

“We cannot agree that the dismissal of [employee’s race] claim was harmless error...”

“[Employee] should have been accorded the right to prepare his case and plan the strategy of trial with the knowledge that the [excluded race] cause of action was properly before the [Lower Tribunal]. Accordingly, we remand the case for trial of [employee]’s claim of racial discrimination consistent with the views set forth below.”

20. Thus, this case gives this Supreme Court the occasion to [similarly] remand this matter (Rule 10(b) – Q2). And Employee X hereby asks this Court to do just that; especially considering the unconstitutionality of the State’s preclusive statutes.

§760 FS is Repugnant to the US Constitution

21. In addition to the State’s specific abuses, Florida’s civil rights statutes are an affront to the US Constitution.

22. §760.11(7) allows the State of Florida to infringe on someone’s [constitutionally-guaranteed] right to access the court. Of course – by that same token – the state statute infringes on people’s [constitutional] rights to trials-by-jury.

23. Put plainly, the State of Florida obstructs litigants’ constitutional rights whenever the State issues a “no cause” determination. Plus, the State can do so with the aide of state-sponsored bribery (§760.06(4) FS).

24. According to this Court, any infringement on a person’s access-to-the-courts is unconstitutional (highlights added):

“This is not to say that economic factors may not be considered, for example, in choosing the methods used to provide meaningful access. But the cost of protecting a constitutional right cannot justify its total denial...”

“The District Court initially held only that petitioners had violated the "fundamental constitutional guarantee," ibid., of access to the courts.”

25. As such, these fundamental impingements (which §760.11(7) FS carries out) meet the textbook definition of unconstitutional (highlights added):

“conflicting with some provision of the Constitution. A statute found to be unconstitutional is considered void or as if it had never been”

26. The textbook solution – as foretold by the US Supreme Court – is to render the statute void (highlights added):

“The Circuit Court held the [state] statute unconstitutional as infringing on the freedom of the press, and dismissed the action...”

“Appellant contends the statute is void on its face because it purports to regulate the content of a newspaper in violation of the First Amendment...”

“It has yet to be demonstrated how governmental regulation of this crucial process can be exercised consistent with First Amendment guarantees of a free press as they have evolved to this time. Accordingly, the [statute is unconstitutional]. It is so ordered.”

27. Thus, Employee X hereby asks this Supreme Court to [further] grant certiorari (on the grounds of an unconstitutional state statute – Rule 10(c) {Q3}). Whereby a full briefing can proceed.

CONCLUSION

WHEREFORE, Petitioner (Employee X) respectfully asks this Court to issue a writ of certiorari to review: (i) the [illegal] departures from law; (ii) the contravention of Supreme Court precedent; and (iii) the constitutionally-violative nature of a Florida Statute.

Dated this 20th day of February 2026.

Respectfully submitted,

/s/ Elias Makere
Elias Makere, FSA, MAAA
Petitioner/Appellant/Plaintiff (“Civilian X”)
PO Box 324
Hobart, IN 46342
P: 904.294.0026
E: Justice.Actuarial@gmail.com
W: TextBookDiscrimination.com
Get Booked Up on Justice!

CERTIFICATE OF COMPLIANCE

1. Type-Volume

☒	This document complies with the word limit of Rule 32(a)(7)(B)(i) Fed. R. App. P., because - excluding the parts of the document exempted by Rule 32(f) - this document contains 1,322 words.

☐	This brief complies with the line limit prescribed by Rule 32(a)(7)(B)(i) Fed. R. App. P., because – excluding the parts of the document exempted by Rule 32(f) – this document contains [NNNN] lines of monospaced text.

2. Typeface and Type-Style

☒	This document uses Courier New (12-Pt) Font; thereby complying with the typeface requirements of Rule 32(a)(5)(B) Fed. R. App. P.. This document also satisfies the type-style requirements of Rule 32(a)(6).

2/20/2026 /s/ Elias Makere
Date Elias Makere, FSA, MAAA

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that – on this 20th day of February 2026 – I electronically filed the foregoing with the Clerk of Courts by using PACER; which will send a notice of electronic filing to the attached service list (Rule 29 Sup. Ct. R.).

Moreover, I HEREBY CERTIFY that I mailed the foregoing to the US Supreme Court (1 First St NE; Washington DC, 20543); doing so via ______ – on February __, 2026.

/s/ Elias Makere

Endnotes:

^1/ Petitioner cites this/these external local rules as persuasive authority only. Petitioner is aware that this court has its own set of local rules.

^2/ please see Rule 13(3) Sup. Ct. R.

10/29/25 = Date that USCA11 entered its decision

11/13/25 = Date that Employee X filed a [timely] ‘Petition for Rehearing’

12/17/25 = Date that USCA11 entered its ‘Denial of Rehearing’

Electronic Copy (text-searchable, hyperlinked):

TextBookDiscrimination.com/Files/CA11/24011336_P_20260220_120006.pdf

Link to Underlying Complaint (HTML, PDF, Video) | Makere v Allstate

HTML	TextBookDiscrimination.com/Allstate/Complaint-Full
PDF	TextBookDiscrimination.com/Files/USFLMD/20000905_AAC_20211104_230439.pdf
VIDEO	https://youtu.be/e3mgBPHesXg

Link to State Judge’s Perjury (HTML, PDF, Video)

HTML	TextBookDiscrimination.com/Cases/Misc/ALJPerjury/Complaint-Amended
PDF	TextBookDiscrimination.com/Files/USFLND/21000096_AAC_20211231_123954.pdf
VIDEO	https://youtu.be/_RaJXFfXOCE

SERVICE LIST

Kimberly J. Doud, Esquire (0523771)
Lauren C. Robertson, Esquire (1024845)

E: kdoud@littler.com
E: lcrobertson@littler.com
P: 407.393.2900
F: 407.393.2929

Littler Mendleson, PC
111 North Orange Avenue, Suite 1750
Orlando, FL 32801-2366

(appellee’s trial lawyers)

Congratulations! You're now Booked Up on the Petition for a Writ of Certiorari that a Floridian filed in Judge Edward Gary Early's civil perjury case.

Please get the justice you deserve.

Sincerely,

www.TextBookDiscrimination.com

R | APPEAL | PETITION FOR A WRIT OF CERTIORARI (Makere v Allstate; §1981, 1985, EPA, FCRA, Title VII)

QUESTION PRESENTED

DISCLOSURES

UNITED STATES SUPREME COURT
Makere v Allstate, 24-____

----

----

TABLE OF CONTENTS

TABLE OF AUTHORITIES

CASES

RULES

STATUTES (FEDERAL)

STATUTES (STATE)

CONSTITUTIONS

ABBREVIATIONS

JURISDICTIONAL BASIS

Introduction

Timeliness

CONSTITUTIONAL PROVISIONS/STATUTES

STATEMENT OF THE CASE

Ultimate Facts

Procedural History

ARGUMENT IN SUPPORT OF A WRIT OF CERTIORARI

The Proceedings From Below Effectuated a Miscarriage of Justice

The Lower Court Proceedings Defied Supreme Court Precedent

§760 FS is Repugnant to the US Constitution

CONCLUSION

CERTIFICATE OF COMPLIANCE

CERTIFICATE OF SERVICE

Endnotes:

SERVICE LIST

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R | APPEAL | PETITION FOR A WRIT OF CERTIORARI (Makere v Allstate; §1981, 1985, EPA, FCRA, Title VII)

QUESTION PRESENTED

DISCLOSURES

UNITED STATES SUPREME COURTMakere v Allstate, 24-____

----

----

TABLE OF CONTENTS

TABLE OF AUTHORITIES

CASES

RULES

STATUTES (FEDERAL)

STATUTES (STATE)

CONSTITUTIONS

ABBREVIATIONS

JURISDICTIONAL BASIS

Introduction

Timeliness

CONSTITUTIONAL PROVISIONS/STATUTES

STATEMENT OF THE CASE

Ultimate Facts

Procedural History

ARGUMENT IN SUPPORT OF A WRIT OF CERTIORARI

The Proceedings From Below Effectuated a Miscarriage of Justice

The Lower Court Proceedings Defied Supreme Court Precedent

§760 FS is Repugnant to the US Constitution

CONCLUSION

CERTIFICATE OF COMPLIANCE

CERTIFICATE OF SERVICE

Endnotes:

SERVICE LIST

Pages That YouMight Also Like

add a comment

thank you, come again!TBD 1.037

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That Will Test Another User's Page-Specific Knowledge

UNITED STATES SUPREME COURT
Makere v Allstate, 24-____

Pages That You
Might Also Like

thank you, come again!
TBD 1.037