Petition for Writ of Certiorari — José L. Yeyille, Petitioner v. The Florida Bar

JAN 07 2026

NO.

IN THE SUPREME COURT OF THE UNITED STATES

JOSE YEYILLE

Petitioner,

v.

THE FLORIDA BAR

Respondent.

PETITION FOR A WRIT OF CERTIORARI TO

THE FLORIDA SUPREME COURT

Jose Yeyille, PRO SE

Citizen Jose

5505 SW 135th Court

Miami, Florida 33175

joseyeyille25@outlook.com

rDECEIVED ’

j MAR 3 I

QUESTIONS PRESENTED

1.

Right to Counsel: Whether the Florida Supreme Court and its agent,

The Florida Bar, deprived me, an indigent man, of my right to be

represented by counsel protected by the Due Process and Equal

Protection Clauses of the Fourteenth Amendment and the Sixth

Amendment to the U.S. Constitution before, during, and after

disciplinary proceedings against me—who had at all relevant times

proceeded as a common citizen—for alleged violations of Rules

Regulating The Florida Bar (RRTFB) which are indistinguishable

from criminal statutes punishing libel against the government

(judiciary).

2.

VLTRA-VIRES: Whether the Florida Supreme Court and its agent,

The Florida Bar, acted beyond their jurisdiction—VLTRA’VIRES—

by harassing and prosecuting me, a layperson (Citizen Jose) who at

all relevant times proceeded only in his personal capacity, for libel

against the government (judiciary), and then extorting and suspending

attorney Jose Yeyille for ninety-one days for alleged violations of

RRTFB indistinguishable from criminal statutes punishing libel

against the government (judiciary), violated my rights to Free

Speech and Free Association, and to Petition the Government for

a Redress of Grievances protected by the First Amendment to the

U.S. Constitution.

3.

Anti-SLAPP: Whether the Florida Supreme Court’s and its agent,

The Florida Bar’s complaint and prosecution against me for criticizing

The judiciary of the state of Florida (public issues in court filings)

and denying to me the right to challenge the Report of Referee, and to

dismiss their inquisition under Florida Anti-SLAPP Statute §768.

295(4) violated my rights to Free Speech, Free Association, and to

Access the Courts, to Petition the Government (judiciary) for a

Redress of Grievances protected by the First Amendment, and

my rights to a Fair Trial, Due Process, and Equal Protection

protected by the First Amendment to the U.S. Constitution.

i

4*

4.

Absolute Litigation Privilege: Whether the Florida Supreme Court

and its agent, The Florida Bar, violated my right to absolute litigation

immunity and my rights to Free Speech and Due Process and Equal

Protection protected by the U.S. Constitution because, in my

capacity as common citizen, I criticized the judiciary of the state of

Florida and a law firm in court filings.

5.

First Amendment: Whether the Florida Supreme Court and its agent

The Florida Bar’s prosecution against me for Rules Regulating

The Florida Bar which are indistinguishable from criminal statutes

punishing libel against the government (judiciary) deprived me of

my rights to Free Speech, Free Association, and to Petition the

Government for a Redress of Grievances protected by the First

Amendment to the U.S. Constitution for criticizing the judiciary

of the state of Florida (public issues) exclusively in court filings.

5.

Vagueness and Overbreath: Whether the Florida Supreme Court and

its agent The Florida Bar harassed, prosecuted, and extorted me for the

alleged violation of Rules Regulating The Florida Bar which are so

incurably vague and overbroad that they can be deceptively wielded as

criminal statutes to punish conduct in a way which they cannot

otherwise constitutionally achieve.

6.

Right to Jury Trial: Whether the Florida Supreme Court and its

agent, The Florida Bar’s prosecution against me for Rules Regulating

The Florida Bar which are indistinguishable from criminal statutes

punishing libel against the government (judiciary) entitles me to

the right to a jury trial protected by the Sixth Amendment to the

U.S. Constitution.

ii

LIST OF PARTIES TO THE PROCEEDING

Jose Yeyille.

The Florida Bar.

STATEMENT OF RELATED PROCEEDINGS

Florida Bar v. Yeyille, SC2024-0235 (October 24, 2025)

Florida Bar v. Yeyille, 2024 WL 4903524, No. SC2024-0235

(Fla. Nov. 27, 2024)

Florida Bar v. Yeyille, SC2024-0235 (May 21,2024)

Jose Yeyille v. Justin Speigel, 3D23-2147 (3rd DCA April 4, 2024).

Jose Yeyille v. Dinah Stein, et al., 3D24-418 (3rd DCA April 4, 2024)

Jose Yeyille v. Glenn Falk, et al., 3D23-0926 (3rd DCA Aug. 25, 2023)

Yeyille v. Speigel, 373 So. 3d 1238 (Fla. 3d DCA June 14, 2023)

Hi

TABLE OF CONTENTS

Page

QUESTIONS PRESENTED FOR REVIEW

i-ii

LIST OF PARTIES

iii

STATEMENT OF RELATED PROCEEDINGS.................................

iii

INDEX OF APPENDICES

v

TABLE OF AUTHORITIES CITED

vii

OPINIONS BELOW

1

JURISDICTIONAL STATEMENT

1

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

1

STATEMENT OF THE CASE

3

REASONS FOR GRANTING THE WRIT

8

I. Indigent laypersons and/or attorneys have the right to be represented

by attomey(s) hired and paid by state Bars and supreme courts at every

stage of state Bars’ disciplinary proceedings pursuant to the commands

of the Due Process and Equal Protection Clauses of Amendment XIV,

International Law, and Amendment VI of the U.S. Constitution

10

A. Due Process (Amendment XIV)

11

B. International Law. Basic Principles on the Role ofLawyers.

Adopted by the Eighth United Nations Congress on the Prevention of

Crime and the Treatment of Offenders, Havana, Cuba,

27 August to 7 September 1990

12

C. American Bar Association. Model Rules for Lawyer Disciplinary

Enforcement

13

D. Equal Protection (Amendment XIV)

14

E. Sixth Amendment

15

The Weeds

19

II. The Florida Supreme Court did not have Jurisdiction to subject a

Layperson to Disciplinary Proceedings........................................................... 19

III. The Florida Bar does not have subject matter jurisdiction to

harass and prosecute me—Citizen Jose.......................................................... 21

IV. VLTRA VIRES: The Florida Bar (Florida Supreme Court), Bar

Counsels, Referee, and Justices harassed, prosecuted, and extorted me

beyond their authority..................................................................................... 22

V. Absolute Litigation Privilege............................................................... 25

VI. Right to Free Speech, Free Association, and to Petition the

Government (the Judiciary) for a Redress of Grievances. (Amendment I)..... 26

A. Free Speech........................................................................................... 26

B. Free Association.................................................................................... 28

C. Petition the Government for a Redress of Grievances and to

Access the Courts............................................................................................ 29

VII. NEMOTVDEXINCAVSAMSVAM............................................. 29

VIII. Florida Statute §768.295 (Anti-SLAPP).......................................... 31

IX. Vagueness and Overbreadth of RRTFB............................................ 31

CONCLUSION............................................................................................... 32

APPENDIX

APPENDIX A: Florida Bar v. Yeyille, SC2024-0235 (October 24, 2025)

Motion for Rehearing denied......................................................................... la

APPENDIX B: Florida Bar v. Yeyille, 2024 WL 4903524, No. SC20240235. (Fla. Nov. 27, 2024). Order striking my Motion to Dismiss the

Report of Referee and Motion to Dismiss and Actual Compensatory

Damages pursuant to Anti-SLAPP §768.295(4) because they.. .did not

“contest” the Report of the Referee (“uncontested report of the referee

is approved” (court’s words-not a typographical error) and denying

v

as moot my Emergency Petition(s) for Writs of MANDAMVS/

Prohibition/All Writs to Command Referee and The Florida Bar to Hire

and Appoint Attomey(s) to Represent Indigent Respondent; and

suspending attorney Jose Yeyille for 91 days and extorting attorney

Jose Yeyille of $2,286.52................................................................................ 3a

APPENDIX C: Florida Bar v. Yeyille, SC2024-0235 (May 21,2024).

Emergency Petition for Writ of Prohibition/All Writs demanding

to be represented by attorney (denied)............................................................ 5 a

APPENDIX D: Jose Yeyille v. Dinah Stein, et al., 3D24-418.

(3rd DCA April 4, 2024). Appeals filed by attorneys are not the

same as PROSE appeals............................................................................... 6a

APPENDIX E: Jose Yeyille v. Justin Speigel, 3D23-2147

(3rd DCA April 4, 2024). Appeals filed by attorneys are not the

same as PRO SE appeals............................................................................... 8a

APPENDIX F: Jose Yeyille v. Glenn Falk, et al., 3D23-0926

(3rd DCA Aug. 25, 2023). Appeals filed by attorneys are not the

same as PRO SE appeals............................................................................... 10a

APPENDIX G: Yeyille v. Speigel, 373 So. 3d 1238 (Fla. 3d DCA,

June 14, 2023). Order referring “matter to the Florida Bar for

appropriate disciplinary proceedings against Jose Yeyille,

Esquire” and banning “further pro se filings submitted by

Jose Yeyille” not Jose Yeyille, Esq............................................................... Ila

vi

TABLE OF AUTHORITIES CITED

CASES

Page Number

Adams v. Robertson, 520 U.S. 83, 86 (1997).................................................... 8

Aetna Life Insurance v. Lavoie, 475 U.S. 813 (1986)..................................... 31

Am. Sch. ofMagnetic Healing v. McAnnulty, 187 U.S. 94 (1902).................. 22

Baldwin v. New York, 399 U.S. 66 (1970)...................................................... 16

Borough ofDuryea v. Guarneri, 564 U.S. 379 (2011)................................... 29

Bridges v. California, 314 U.S. 252 (1941)..................................................... 28

Brinkerhoff-Faris Co. v. Hill, 281 U.S. 673 (1930)..................................... 3, 11

Brown v. State, 356 U.S. 148 (1958)................................................................ 27

Brown v. Western R. Co. ofAlabama, 338 U.S. 294 (1949).............................. 9

Calderon v. Moore, 518 U.S. 149 (1996)......................................................... 10

California Transport v. Trucking Unlimited, 404 U.S. 508 (1972).................. 29

Chaffin v. Chaffin, 568 U.S. 165 (2013).....................................

10

Church ofScientology of Cal. v. United States, 506 U.S. 9 (1992).................. 10

Citizens United v. Fed. Election Comm ’n, 558 U.S. 310 (2010)..................... 26

City ofDallas v. Stewart, 361 S.W. 562 (Tex. 2012)...................................... 23

Connickv. Myers, 461 U.S. 138 (1983)............................................................ 27

Cunningham v. Standard Guar. Ins. Co., 630 So. 2d 179 (Fla. 1994).............. 22

vii

Davis v. Wechsler, 263 U.S. 22 (1923)......................................................... 9, 31

Duncan v. Louisiana, 391 U.S. 145 (1968)...................................................... 15

ExParte Garland, 71 U.S. 333 (1867)............................................................ 12

Florida Bar re Amendments to Rules, 624 So. 2d 720 (Fla. 1993).................. 20

Florida Bar v. Yeyille, 2024 WL 4903524, No. SC2024-0235

(Fla. Nov. 27, 2024)

1, 8 (APPENDIX B)

Florida Bar v. Yeyille, SC2024-0235 (October 24, 2025).. .1,8 (APPENDIX A)

Floridians Against Inflated Rates, Inc. v. Clark,

No. SC2021-1761 (Fla. Sep.28, 2023)............................................................. 24

Garrison v. Louisiana, 379 U.S. 64 (1964)................................................21,27

Gentile v. State Bar ofNevada, 501 U.S. 1030 (1991)..................................... 26

Gibson v. Berryl, 411 U.S. 564 (1973).............................................................. 8

Goldberg v. Kelly, 397 U.S. 254 (1970)........................................................... 11

Grayned v. City ofRockford, 408 U.S. 104 (1972).......................................... 32

Greene v. McElroy, 360 U.S. 474 (1959)........................................................ 11

Harmon v. Brucker, 355 U.S. 579 (1958)....................................................... 22

Henry v. Mississippi, 379 U.S. 443 (1965)....................................................... 10

Hensley v. State Commission on Judicial Conduct, et al.,

692 S.W. 3d 184 (Tex. June 28, 2024).......................................................22, 23

Howlett v. Rose, 496 U.S. 356 (1990).................................................... 9, 13, 21

In re Murchison, 349 U.S. 133 (1955)............................................................. 31

viii

In re Primus, 436 U.S. 412 (1978)................................................................... 27

Int’I Truck & Engine Corp. v. Cap. Truck, Inc.,

872 So.2d 372 (Fla. 1st DCA 2004).................................................................24

Janus v. American Fed’n of State, Cnty. & Mun. Emps., Council 31,

138 S. Ct. 2448 (2018).................................................................................... 28

Jose Yeyille v. Dinah Stein, Esq. et al., 3D24-418. (April 3, 2024)...... 1, 20, 25

Jose Yeyille v. Justin Cole Speigel,

373 So. 3d 1238, 1240 (Fla. 3d DCA June 14, 2023).......................... 1, 3, 4, 20

Jose Yeyille v. Justin Cole Speigel, M.D., 3D-2023-2147

(April 3, 2024)........................................................................................ 1, 20, 25

Jose Yeyille v. Glenn Falk, Esq., 3D-2023-926 (August 2, 2023)............... 1, 20

Keller v. State Bar of Cal., 496 U.S. 1 (1990)................................................. 28

Landmark Communications, Inc. v. Virginia, 435 U.S. 829 (1978)................ 26

Levin, Middle-brooks v. U.S. Fire Ins. Co, 639 So.2d 606 (Fla. 1994)........ ...25

Liberty Counsel v. Florida Bar Board of Governors,

12 So. 3d 183 (2009)...................................................................................... 24

Loper Bright Enterprises, et al. v. Raimondo, Secretary of

Commerce, etal., No. 22-451, June 28, 2024, 603 U.S.(2024)..............22

Malone v. Meres, 91 Fla. 709 (Fla. 1926)....................................................... 19

Marshall v. Jerrico, Inc., 446 U.S. 238 (1980)............................................... 11

Memphis Light, Gas Water Div. v. Craft, 436 U.S. 1 (1978)......................... 12

Meyer v. Nebraska, 262 U.S. 390 (1923)........................................................ 12

ix

Mullane v. Central Hanover Bank and Trust Co., 339 U.S. 306 (1950)

11

N.A.A.C.P. v. Button, 371 U.S. 415 (1963)

26

New York Times Co. v. Sullivan, 376 US 254 (1964)

16, 21, 27

Pacific Gas & Elec., Co. v. Public Util. Comm’n, 475 U.S. 1 (1986)

28

Pennekamp v. Florida, 328 U.S. 331 (1946)

27

Roberts v. United States Jaycees, 468 U.S. 609 (1984)

28

Shelley v. Kraemer, 334 U. S. 1 (1948)

14

Snyder v. Phelps, 562 U.S. 443 (2011)

27

Sperry v. Florida, 373 U.S. 379 (1963)

20

Sweatt v. Painter, 339 U.S. 629 (1950)

14

The Florida Bar v. Furman, 451 So. 2d 808 (Fla. 1984)

20

The Fla. Bar v. Jacobs, No. SC2020-1602 (Fla. Jun. 8, 2023)

17

The Fla. Bar v. Maynard, 672 So. 2d 530 (1996)

18

The Florida Bar v. Nieman, 816 So. 2d 587 (Fla. 2002).............................. .20

The Florida Bar re Schwarz, 552 So. 2d 1094 (Fla. 1989)

23

The Florida Bar v. Jose L Yeyille, SC2024-0235 (Fla. Feb. 15, 2024)

6

Truax v. Corrigan, 257 U.S. 312 (1921)

9

Tumey v. Ohio, 273 U.S. 510 (1927)

30

U.S.A, v. ChiefJudge George L. Russell, l:25-cv-02029

(Dist. Ct. Maryland June 24, 2025)

27

x

United States v. Trump, 88 F.4th 990 (D.C. Cir. 2023)

27

Virginia v. Hicks, 539 U.S. 113 (2003)

32

Warren v. DeSantis, 90 F.4th 1115 (Cir. January 11, 2024)

21

Williams-Yulee v. Florida Bar, 135 S. Ct. 1656 (2015)

9, 15

Yormak v. Yormak (In re Yormak), 640 B.R. 491 (M.D. Fla. 2022)

20

FEDERAL STATUTES AND RULES

U. S. Constitution, Article VI

10, 21

U. S. Constitution, Amendment I

i, ii, 1, 2, 5, 6, 18, 26-29

U.S. Constitution, Amendmmt VI

i, ii, 1, 10, 13, 15, 21

U. S. Constitution, Amendment XIV

28U.S.C. §1257(a)

i, ii, 2, 7, 8, 10-12, 14, 15, 26-29

1

Basic Principles on the Role ofLawyers. Adopted by the Eighth United

Nations Congress on the Prevention of Crime and the Treatment of

Offenders, Havana, Cuba, 27 August to 7 September 1990

2, 12,13

Florida Statutes and Rules

Art. V, §15, Florida Constitution

19

Florida Rule of Criminal Procedure 3.840

16

Florida Statute §768.295 (Anti-SLAPP)

Florida Statute §836.01

(RRTFB) Rules Regulating The Florida Bar

i, 2, 8, 9, 23, 31

15

i, ii, 2,3,6, 14, 16, 17, 23, 31

Referee Manual. The Florida Bar. Revised February 2024........................... 18

Other

American Bar Association. Model Rules for Lawyer Disciplinary

Enforcement.............................................................................................. 2, 13

Black's Law Dictionary. Second Edition (1910)...................................... 18, 24

Blasphemy and the Original Meaning of the First Amendment.

135 Harv. L. Rev. 659 (2021).........................................................................18

“Greenberg Traurig P.A. ’s Barry Richard Obtains Supreme Court

Decision in Favor ofLongtime Client The Florida Bar.” May 1,2015.

(Greenberg Traurig P.A.’s website)................................................................15

Inquisitorial Inquiries: BriefLives of Secret Jews and Other Heretics,

Edited and Translated by Richard Kagan and Abigail Dyer.

(2d ed., Johns Hopkins University Press, 2011).............................................18

Legal Information Institute. Cornell Law School).......................................... 17

Louise Lark Hill. The Litigation Privilege: Its Place in Contemporary

Jurisprudence. Hofstra Law Review. Vol 44. Issue 2. (Dec. 1, 2015).......... 26

Michael A. Mora. Third DCA Sanctions Miami Lawyer But Avoids

Underpinning Issues. ALM/Law.com. June 16, 2023, 01:34 PM........... 4, 5

The Florida Bar. What we Do. Website.........................................................31

The trial offaith in the Spanish Inquisition: Between Law and

Repentance. Jean-Pierre Dedieu and Gundmar W. Knutsen.

Cambridge University Press (2023)............................................................. 18

Warren Adrian Rachels. Lawyer Discipline. The Florida Bar. Vol. 95,

No.3. May/June 2021, Pg. 6......................................................................... 18

xii

OPINIONS BELOW

Florida Bar v. Yeyille, SC2024-0235 (October 24, 2025). Case Closed.

Florida Bar v. Yeyille, 2024 WL 4903524, No. SC2024-0235

(Fla. Nov. 27, 2024)

Florida Bar v. Yeyille, SC2024-0235 (May 21, 2024)

Jose Yeyille v. Dinah Stein, et al., 3D24-418 (3rd DCA April 4, 2024)

Jose Yeyille v. Justin Speigel, 3D23-2147 (3rd DCA April 4, 2024)

Jose Yeyille v. Glenn Falk, et al., 3D23-0926 (3rd DCA Aug. 25, 2023)

Yeyille v. Speigel, 373 So. 3d 1238 (Fla. 3d DCA June 14, 2023).

JURISDICTIONAL STATEMENT

The final judgment of the Florida Supreme Court was issued on October

24,2025.

The jurisdiction of this Court is invoked under 28 U.S.C. §1257(a).

Petitioner kindly petitions this Court for a Writ of CERTIORARI to review

the judgment of the Florida Supreme Court.

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

ARTICLE VI. This Constitution.. .and all treaties made.. .under the

authority of the United States, shall be the supreme law of the land; and the

judges in every state shall be bound thereby, anything in the Constitution or

laws of any State to the contrary notwithstanding.

AMENDMENT I: Congress shall make no law.. .abridging the freedom of

speech.. .or the right of the people peaceably to assemble, and to petition the

government for a redress of grievances.

AMENDMENT VI: In all criminal prosecutions, the accused shall enjoy

the right.. .to an impartial jury.. .and to have the Assistance of Counsel for his

defence.

1 of 32

AMENDMENT XIV: No state shall.. .deprive any person of.. .liberty, or

property, without due process of law; nor deny to any person within its juris­

diction the equal protection of the laws.

Article 27. Disciplinary Proceedings. “Lawyers shall have the right to a

fair hearing, including the right to be assisted by a lawyer of their choice.”

Basic Principles on the Role ofLawyers. Adopted by the Eighth United

Nations Congress on the Prevention of Crime and the Treatment of Offenders,

Havana, Cuba, 27 August to 7 September 1990. (U.S, is signatory).

Rule 18. Model Rules for Lawyer Disciplinary Enforcement. American

Bar Association. Commentary: “... .the license must not be arbitrarily taken

away and the holder is entitled to procedural due process in any proceeding

relating to such conduct. Such due process rights include... right to counsel.”

Rule 34. Model Rules for Lawyer Disciplinary Enforcement. American

Bar Association. “Upon receipt of satisfactory proof of a respondent’s

indigency, the board may request a lawyer to serve as counsel for the

respondent.”

Florida Statute §768.295 (Anti-SLAPP).

§768.295(3):

A person or governmental entity in this state may not file or cause

to be filed, through its employees or agents, any lawsuit, cause of

action, claim, cross-claim, or counterclaim against another person or

entity without merit and primarily because such person or entity has

exercised the constitutional right of free speech in connection with

a public issue, or right to peacefully assemble, to instruct

representatives of government, or to petition for redress of

grievances before the various governmental entities of this state,

as protected by the First Amendment to the United States

Constitution.

§768.295(4):

A person or entity sued by a governmental entity or another person in

violation of this section has a right to an expeditious resolution of a

claim that the suit is in violation of this section. A person or entity

2 of 32

may move the court for an order dismissing the action or

granting final judgment in favor of that person or entity....

The court may award, subject to the limitations in s. 768.28, the party

sued by a governmental entity actual damages arising from a govern­

mental entity’s violation of this section. The court shall award the

prevailing party reasonable attorney fees and costs incurred in connec­

tion with a claim that an action was filed in violation of this section.

Rules Regulating the Florida Bar (“RRTFB”)

3-7-4 GRIEVANCE COMMITTEE PROCEDURES.

3-7-4(h) Rights and Responsibilities of the Respondent. “The respondent

may be accompanied by counsel.”

10.7.2 PROCEEDINGS FOR INDIRECT CRIMINAL CONTEMPT.

10.7.2(b). Indigency of Respondent. “Any respondent who is determined

to be indigent by the referee is entitled to the appointment of counsel.”

STATEMENT OF THE CASE

On June 14, 2023, a panel of the third district court of appeal of Florida issued

a written order referring me to disciplinary proceedings by The Florida Bar on

account that my Motion for Rehearing pursuant to Brinkerhoff-Faris Co. v. Hill,

281 U.S. 673, 680 (1930) (constitutional challenges to that court’s order without

opinion), impugned the qualifications or integrity of the judiciary of the state of

Florida, because I accuse the law firm “Greenberg Traurig P.A. [of] own[ing]

the judges of the Third District Court of Appeal”, and

3 of 32

“that the judges of the judiciary of the state of Florida, from the

district courts of appeals, especially the Third District Court of

Appeal, to the justices of the Florida Supreme Court, are racists and

elitists who deliberately issue PER CURIAM affirmances, in the

vast majority of cases that they decide, to indigents, and indigent

PRO SE Black and Hispanic parties which, in turn, preclude

appeals and petitions for writs to the Florida Supreme Court.”

Jose Yeyille v. Justin Cole Speigel, 373 So. 3d 1238,1240 (Fla.

3d DCA June 14 2023). [APPENDIX G].

Most significantly, the court forbade only Citizen Jose from filing “further

pro se filings”—but not attorney Jose Yeyille—who resumed filing

appeals regarding other cases. [APPENDICES D, E, Fl.

Two days later a distinguished national and international publication

published a distinguished Ethics professor’s statement regarding my case:

“Third DCA Sanctions Miami Lawyer But Avoids Underpinning

Issues.” Michael A. Mora. June 16, 2023, 01:34 PM. ALM/Law.com.

““All of these issues are central to the bar and bench in Florida, all are

surfaced in Yeyille v. Speigel, and all remain unresolved to the

detriment of the rule of law””, said Anthony V. Alfleri of the Uni­

versity of Miami School of Law, who is not involved in the litigation.”

““[The Third DCA per curiam opinion issued on June 14, 2023] was

noteworthy for its avoidance on vital issues underpinning them,”” said

Anthony V. Alfieri of Miami School of Law. Alfleri, the founding

director of the Center for Ethics and Public Service and a professor at

Miami Law, who is not involved in the matter, said in an email that

three issues stood out that ““remain unresolved to the detriment of

the rule of law.””

““First, the increasing court use of per curiam affirmances on appeal.

In fact, from 1983 to 1998, the number of PCAs increased by 92.7%

in Florida District Courts of Appeal,”” Alfieri said. ““Second, the

growing impact of law firm financing of increasingly costly judicial

4 of 32

election campaigns. And third, the rising state-wide controversy over

the role of race in litigation and adjudication.””

September 29, 2023.1 received a Notice of Grievance Committee Review

signed by William Chung, Bar Counsel of the Florida Bar, (“Chung”) threatening

to have a vote “as to whether probable cause is present” to prosecute me in my

capacity as an attorney pursuant to the panel of judges of the third district court

of appeal’s referral.

October 13, 2023,1 sent a letter to Chung and the Grievance Committee

informing them that The Florida Bar and its grievance committee does not have

jurisdiction against citizens and nonlawyers, or any person representing himself

in his individual capacity, and that at all relevant times in that court proceeding,

in my capacity as common U.S. Citizen, I was exercising my rights to Free

Speech on Public Issues, Free Association (not to be forced to associate with an

organization that harasses attorneys and common citizens for exercising our

First Amendment rights), and to Petition the Government (Judiciary) for a

redress of grievances) protected by the First Amendment to the U.S.

Constitution.

October 23, 2023. Chung sent the “Notice of Finding Probable Cause for

Further Disciplinary Proceedings” informing me that they had found probable

cause to prepare a formal complaint accusing me of violating Rules Regulating

5 of 32

the Florida Bar (“RRTFB”) which are undistinguishable from criminal libel

statutes: RRTFB 3-4.3. Misconduct and Minor Misconduct. RRTFB 4-3.1.

Meritorious Claims and Contentions. RRTFB 4-8.2(a) Impugning Qualifications

and Integrity of Judges or Other Officers. RRTFB 4-8.4(d) engage in conduct in

connection with the practice of law that is prejudicial to the administration of

justice.

On February 15, 2024, Bar Counsel Chung and Bar Staff Counsel Patricia

Ann Toro Savitz (“Toro”) filed a complaint against me on behalf of the Florida

supreme court.. .in the Florida supreme court. The Florida Bar v. Jose L

Yeyille, SC2024-0235.

February 16, 2024.1 made the first of 10 requests to the Bar, Referee,

and the Florida supreme court, repeatedly and consistently demanding to be

represented by attomey(s) paid by The Florida Bar on account of my

indigency.1 October 24, 2025, the Florida Supreme Court denied my Motion

for Rehearing closing the case (APPENDIX A). See Florida Supreme

1 February 16, 2024: Motion for Clarification Regarding Referee requesting

that The Florida Bar and Florida supreme court hire an attorney to represent

me in Bar disciplinary proceedings (Ignored by the Florida supreme court,

The Bar and their Referee). April 13, 2024: Emergency Petition for Writ of

Prohibition and/or All Writs filed in Florida supreme court demanding to be

represented by counsel (Denied May 21, 2024) [APPENDIX C]. May 27,

6 of 32

Court’s official ACIS /Courts System www.flc0urts.20v).

2024: Response to Bar’s Motion for Partial Summary Judgment...! am Entitled

to Free Counsel, Transcripts, and Any and All Costs (Denied by the Bar and the

Referee at trial of June 17, 2024). June 16, 2024:1 made written demand to the

Referee and the Bar that the Florida Supreme Court Appoint an Attorney for

His Inquisition, and His Right to Jury Trial (Denied by the Bar and Referee at

trial, June 17, 2024). June 17,2024: Before the trial began, I repeatedly

requested from the Referee and Bar counsel to be represented by counsel, and

a jury trial. (Denied by Bar counsel and Referee). Whereupon I respectfully

told the Referee that I was going to leave. Referee informed me that the trial

will proceed IN ABSENTIAM. Thereupon, I kindly bade farewell to Bar

counsel and Referee ET EXEI, and that same day filed Emergency Petition(s)

for Writ of MANDAMVS and/or Prohibition and/or.. .All Writs to Command

the Referee and The Florida Bar to Hire and Appoint Attomey(s) to Represent

Indigent Respondent for His Inquisition for Libel against the Government—

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REASONS FOR GRANTING THE PETITION

I timely, repeatedly, and “properly presented to the state court that rendered

the decision[s]” all “federal claims” which I kindly ask this Court “to review.”

Gibson v. Berryl, 411 U.S. 564, 577 (1973); Adams v. Robertson, 520 U.S. 83,

86 (1997). The Florida supreme court’s deceptive evasions and refusals to rule

on my constitutional challenges raised in my Motions to Dismiss the Report of

REASONS FOR GRANTING THE PETITION

I timely, repeatedly, and “properly presented to the state court that rendered

the decision[s]” all “federal claims” which I kindly ask this Court “to review.”

Gibson v. Berryl, 411 U.S. 564, 577 (1973); Adams v. Robertson, 520 U.S. 83,

86 (1997). The Florida supreme court’s deceptive evasions and refusals to rule

on my constitutional challenges raised in my Motions to Dismiss the Report of

the Judiciary of the State of Florida (Denied as moot, November 27, 2024).

October 8,2024:1 timely filed Motion to Dismiss the Report of Referee with

Prejudice and Motion to Dismiss pursuant to Florida Statute §768.295(4)

Anti-SLAPP in the Florida supreme court. November 27, 2024: Florida

supreme court’s order striking—and forging and erasing my demand to be

represented by counsel paid by the Florida supreme court and the Bar—

on account that my Motions did not “contest” (“[t]he uncontested report

of the referee is approved”) suspending attorney Jose Yeyille for 91 days,

and extorting from him $2,286.72 for “recovery costs”. [APPENDIX B].

December 2,2024:1 timely file Motion for Rehearing and Clarification.

October 24,2025: Florida supreme court’s order striking it and closing the

case. [APPENDIX A. Case Closedl. See page 7, SVPRA.

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Referee/Anti-SLAPP Statute and Rehearing and Clarification2 does not

immunize it from review by this Court3,4’5; nor does its denials of those same

federal claims raised in emergency petitions for writs of MANDAMVS/

2 “The one belief the Majority, the Florida Supreme Court, and I appear to

share about the Florida Supreme Court is that it has repeatedly acted

deceptively... I believe the Florida Supreme Court acted deceptively.. .1 also

believe the Florida Supreme Court acted deceptively...” Graham v. R.J.

Reynolds Tobacco Co., 857 F.3d 1169,1245 n.273 (11th Cir. 2017). (Judge

Gerald Tjoflat, dissenting). In the Florida supreme court’s justices’ defense,

you High Priests of the Potomac do not have a clue about what judicial

integrity is either. “[Justices of the United States Supreme Court] do[ ] not

even have a consistent theory about what it means by “‘judicial integrity.’”

Williams-Yulee v. Florida Bar, 135 S. Ct. 1656,1680 (2015)(Justice Antonin

Scalia, dissenting).

3

Truax v. Corrigan, 257 U.S. 312,324 (1921):

In cases brought to this Court from state courts for review, on the

ground that a federal right set up in the state court has been wrongly

denied, and in which the state court has put its decision on a finding

that the asserted federal right has no basis in point of fact, or has

been waived or lost, this Court, as an incident of its power to

determine whether a federal right has been wrongly denied, may

go behind the finding to see whether it is without substantial

support. If the rule were otherwise, it almost always would be

within the power of a state court practically to prevent a review

here. (Emphasis).

4 ““Whatever springes the state may set for those who are endeavoring to

assert rights that the state confers, the assertion of federal rights, when plainly

and reasonably made, is not to be defeated under the name of local practice.””

Brown and Western R. Co. ofAlabama, 338 U.S. 294, 298 (1949)(quoting

Davis v. Wechsler, 263 U.S. 22,24 (1923)(emphasis added).

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Prohibition/All Writs immunize it from this Court’s review.6

I. Indigent laypersons and/or attorneys have the right to be

represented by attorney(s) hired and paid by state Bars and supreme

courts at every stage of state Bars’ disciplinary proceedings pursuant

to the commands of the Due Process and Equal Protection Clauses of

Amendment XIV, International Law, and Amendment VI of the U.S.

Constitution.

I am unaware of any binding case law that requires state Bars and supreme

courts to afford attorneys to indigent laypersons and attorneys in disciplinary

proceedings. Nevertheless, The Florida Bar’s, the Referee, and the Florida

supreme court’s repeated indifference, and positive refusals without opinions

or any reference to any binding legal authority to refuse counsel to me is telling

that my case and this Petition are ones of enormous precedential value.

“The federal guaranty of due process [and equal protection] extends to

state action through its judicial as well as through its legislative, executive or

5 United States Constitution, Article VI., Section 2. Supremacy Clause.

Howlett v. Rose, 496 U.S. 356,367 (1990).

6 “[A] state appellate court’s refusal, on the ground of mootness, to consider

a federal claim, did not preclude our independent determination of the question

of mootness; that is itself a question of federal law which this Court must

ultimately decide.” Henry v. Mississippi, 379 U.S. 443,447 (1965). ““Even the

availability of a ‘partial remedy’ is ‘sufficient to prevent [a] case from being

moot.’”” Chaffin v. Chaffin, 568 U.S. 165,177 (2013)(quoting from Calderon

v. Moore, 518 U.S. 149,150 (1996)(per cwz'am)(quoting Church of

Scientology of Cal. v. United States, 506 U.S. 9,13 (1992).

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administrative branch of government.” Brinkerhoff-Faris Co. v. Hill, 281 U.S.

673, 680 (1930)[emphasis mine] (emphasis).

“This Court has been zealous to protect these rights from erosion. It has

spoken out not only in criminal cases.. .but also in all types of cases where

administrative.. .actions were under scrutiny.”” Goldberg v. Kelly, 397 U.S.

254,270 (1970) (quoting Greene v. McElroy, 360 U.S. 474, 496-497 (1959).

A. Due Process (Amendment XIV).

U.S. Constitution. Amendment XIV, Section 1 states in pertinent part:

“No state shall make or enforce any law which shall abridge the

privileges or immunities of citizens of the United States; nor

shall any State deprive any person of.. .liberty, or property,

without due process of law; nor deny to any person within its

jurisdiction the equal protection of the laws.” (Emphasis).

“The Due Process Clause entitles a person to an impartial and disinterested

tribunal in both civil and criminal cases.” Marshall v. Jerrico, Inc., 446 U.S.

238,242 (1980). “At a minimum.. .deprivation of life, liberty or property by

adjudication [must] be preceded by notice and opportunity for hearing

appropriate to the nature of the case.” Mullane v. Central Hanover Bank and

Trust Co., 339 U.S. 306,313 (1950).

My Liberty: “The attorney.. .being by the solemn judicial act of the court

clothed with his office, does not hold it as a matter of grace and favor. The

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right which it confers upon him to appear for suitors and to argue cases is

something more than a mere indulgence, revocable at the pleasure of the

court.” Ex Parte Garland, 71 U.S. 333, 379 (1867). An attorney has the

liberty right to engage in his occupation free of arbitrary interference from the

government (judiciary). Meyer v. Nebraska, 262 U.S. 390,399-400 (1923):

While this Court has not attempted to define with exactness the

liberty thus guaranteed, the term has received much consideration

and some of the included things have been definitely stated.

Without doubt, it denotes not merely freedom from bodily restraint

but also the right of the individual to contract, to engage in any of

the common occupations of life.... The established doctrine is that

this liberty may not be interfered with, under the guise of protecting

the public interest, by legislative action which is arbitrary or without

reasonable relation to some purpose within the competency of the

State to effect. Determination by the legislature of what constitutes

proper exercise of police power is not final or conclusive but is

subject to supervision by the courts.

My Property: A license to practice law is property because “it may [be]

terminated.. .only ““for cause,”” respondents assert a ““legitimate claim of

entitlement”” within the protection of the Due Process Clause.” Memphis Light,

Gas Water Div. v. Craft, 436 U.S. 1,11-12 (1978). See also Ex Parte Garland

(1867). SVPRA.

B. International Law: Article 27. Disciplinary Proceedings. “Lawyers

shall have the right to a fair hearing, including the right to be assisted by a

lawyer of their choice.” Basic Principles on the Role ofLawyers. Adopted

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by the Eighth United Nations Congress on the Prevention of Crime and

the Treatment of Offenders, Havana, Cuba, 27 August to 7 September

1990. (Emphasis).*—<—The United States is a signatory to this Treaty. U.S.

Constitution, ARTICLE VI: This Constitution.. .and all treaties made...

under the authority of the United States, shall be the supreme law of the land;

and the judges in every state shall be bound thereby, anything in the

Constitution or laws of any State to the contrary notwithstanding. Howlett v.

Rose, 496 U.S. 356,371 (1990).

C. American Bar Association. Model Rules for Lawyer Disciplinary

Enforcement:

Rule 18. Commentary:

. ..the license must not be arbitrarily taken away and

the holder is entitled to procedural due process in any proceeding relating to such

conduct. Such due process rights include... right to counsel.” (Emphasis).

Rule 34. “Upon receipt of satisfactory proof of a respondent’s indigency, the

board may request a lawyer to serve as counsel for the respondent.” (Emphasis).

Rules Regulating The Florida Bar:

3-7-4(11) Rights and Responsibilities of the Respondent. “The respondent

may be accompanied by counsel.” (Emphasis).

10-7.2(b). Indigency of Respondent. “Any respondent who is determined to

be indigent by the referee is entitled to the appointment of counsel.”

(Emphasis).

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Therefore, these binding legal authorities guarantee an indigent layperson or

attorney the constitutional and legal rights to be represented by counsel paid

by The Florida Bar Bar and the Florida supreme court) at every state of a

disciplinary proceeding.

D. Equal Protection. (Amendment XIV).

“Central both to the idea of the rule of law and to our own Constitution’s

guarantee of equal protection is the principle that government and each of its

parts remain open on impartial terms to all who seek its assistance.” ‘Equal

protection of the laws is not achieved through indiscriminate imposition of

inequalities.

Sweatt v. Painter, 339 U.S. 629, 635 (1950)(quoting Shelley

v. Kraemer, 334 U. S. 1, 22(1948).”

The Florida Bar (Florida supreme court) hires and pays attomey(s) to

represent nonlawyers accused of practicing law without a license. RRTFB

10-7.2(b).

The Florida supreme court /The Bar hires and pays Greenberg Traurig,

P.A. to represent them in lawsuits filed against the Florida supreme court/The

Bar; therefore, the Florida supreme court/The Bar must hire and pay

attorney(s) to represent me at every stage of their prosecution against me, too.

The Florida Bar and the Florida supreme court must treat me the same way

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they treat their “Longtime” attorneys of the law firm Greenberg Traurig,

P.A.7

E. Sixth Amendment.

At all stages in The Florida Bar (Florida supreme court)’s threats to prosecute

me, and then prosecuting me, and suspending attorney Jose Yeyille’s license and

extorting him for the cost of his prosecution for the alleged violation of RRTFB

which are in fact criminal statutes proscribing libel against the government

(judiciary) masquerading as RRTFB, I prominently and repeatedly demanded—

and was prominently and repeatedly denied—from the Bar, Bar Counsel, the

Referee, and the Florida supreme court my right to be represented by counsel(s)

hired and paid by them.

Amendment VI applies to the states through Amendment XIV. Duncan v.

Louisiana, 391 U.S. 145 (1968).

Florida Statute §836.01 Punishment for Libel.—Any person convicted of

the publication of a libel shall be guilty of a misdemeanor of the first degree,

7 “Greenberg Traurig P.A.’s Barry Richard Obtains Supreme Court

Decision in Favor of Longtime Client The Florida Bar.” May 1, 2015.

(Greenberg Traurig P.A.’s website). The case: Williams-Yulee v. Florida

Bar, 135 S. Ct. 1656 (2015).

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punishable a provided in s. 775.082 or s. 775.083.

“[A] definite term of imprisonment not exceeding 1 year”, §775.082

(4)(a), and /or “1,000 fine”, §775.083(l)(d).”

Florida Rule of Criminal Procedure 3.840 indirect criminal contempt is

punishable by a “fine.. .not [to] exceed $500 nor the imprisonment 12

months.” Florida Statute §775.02.

“For good reason, ““no court of last resort in this country has ever held, or

even suggested, that prosecutions for libel on government have any place in the

American system of jurisprudence.”” (emphasis). New York Times Co. v.

Sullivan, 376 US 254, 291-292 (1964) (E/wp/i avis added).

In Baldwin v. New York, 399 U.S. 66 (1970) this Court held that

“administrative conveniences “can[not].. .justify denying an accused the

important right to trial by jury where the possible penalty exceeds six months’

imprisonment.” [Emphasis mine]. I kindly urge this Court to go further and

adopt Justices Black’s and Douglas’ dissent:

“Not all official sanctions are imposed in criminal

proceedings, but when, as in this case, the sanction

bears all the indicia of a criminal punishment, a

jury trial cannot be denied by labeling the

punishment ““petty.””” (ID. at 76, n.2)

Disciplinary Proceedings are Judicial Proceedings. RRTFB 3—7.6(f)(1)

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states that disciplinary proceedings against attorneys are “Administrative in

Character. A disciplinary proceeding is neither civil nor criminal but is a

quasi-judicial administrative proceeding.” Yet, “[t]he Florida Rules of Civil

Procedure apply.” (IBID.)

Chief justice Carlos Muniz appointed judge Carlos Guzman to be “referee”

in Citizen Jose’s Inquisition. RRTFB 3—7.6(a)(1). Justice and referee put the

judicial injudicial proceedings. “A judicial proceeding is a proceeding over

which a judge presides.” {Legal Information Institute. Cornell Law School).

The Florida supreme court explains that they are “adversary proceedings”

RRTFB 3—7.6(b); in a court RRTFB 3—7.6(d); with a “pretrial conference”

RRTFB 3—7.6(c). The “Style of Proceedings” are the same as those used in

court filings in criminal cases RRTFB 3—7.6(e). Cases against attorneys

(and now also common citizens) are prosecuted by Bar counsels RRTFB

3—7.6(g) chosen by Staff Counsels chosen by the Board of Governors all of

them agents of the Florida supreme court RRTFB 3—3.3.

As in criminal trials, Respondents are found “guilty”. “Guilty” has always

been a verdict reserved for criminal cases.8 See The Fla. Bar v. Jacobs, No.

SC2020-1602, p. 2 (Fla. Jun. 8, 2023): “We approve the referee’s findings of

fact and recommendations as to guilt.” All the procedures before the “referee”

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are undistinguishable from procedures before a judge in a criminal trial except

that there are no rules of evidence, no jury, and no right to confront witnesses

is allowed.9,10 The Fla. Bar v. Maynard, 672 So. 2d 530 (1996). Referee

Manual The Florida Bar. Revised February 2024, pgs. 5-13.

8 “[T]he word used by a prisoner in pleading to an indictment when he

confesses the crime of which he is charged, and by the jury in convicting.”

Black’s Law Dictionary. Second Edition (1910).

9 “The respondent in the ‘Court of the Star Chamber’ probably had more

rightsthan the respondent in the Florida Lawyer Discipline System.” Warren

Adrian Rachels. Lawyer Discipline. The Florida Bar. Vol. 95, No.3.

May/June 2021, pg. 6.

10 Established to combat heresy, the Tribunal del Santo Oficio de la Inquisition,

known elsewhere as the Spanish Inquisition, afforded more due process

protections than the Florida supreme court through its ALTER-EGO The Florida

Bar. Those tried by the Inquisition had the right to have a defense attorney

appointed by the Santo Oficio and free transcripts of their trials. Inquisitorial

Inquiries: BriefLives of Secret Jews and Other Heretics, Edited and Translated

by Richard Kagan and Abigail Dyer. (2d ed., Johns Hopkins University Press,

201 l).77ze trial offaith in the Spanish Inquisition:Between Law and Repentance.

Jean-Pierre Dedieu and Gundmar W. Knutsen. Cambridge University Press

(2023). Blasphemy was a crime punished in the common law by the state.

“Blasphemy and the Original Meaning of the First Amendment. ” 135 Harv. L.

Rev. 659 (2021). A significant percentage of the Inquisition’s trials ended with

the accused being found innocent. (See Inquisitorial Inquiries and The trial of

faith, IBID.). The Inquisition did not have jurisdiction to prosecute Jews

and Muslims. The Florida supreme court’s justices’ disciplinary prosecutions

against attorneys have never ended finding one attorney innocent; that is 100%

prosecutorial success right there. They prosecuted me even though they do not

jurisdiction to prosecute laypersons. See INFRA. I’d rather be a Muslim or a

Jew in XVII Century Spain than a layperson in Florida today.

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Therefore, in addition to hire and pay attorney [s] to represent me because it

accused and prosecuted me of committing the crime of libel, The Florida Bar

and the Florida supreme court must grant me the right to a trial by jury.

ATTENTION: If this Court decides to grant me this Petition on account that

I, an indigent common citizen and/or attorney, was entitled to an attorney hired

and paid by the Bar at all stages of the Bar’s disciplinary proceedings against

me, then, I reckon it would be unnecessary to get further into the weeds of this

Petition. But, if this Court is not persuaded that I had the right to counsel, then

I urge this Court to get further in the weeds of this Petition.

The Weeds

II. The Florida Supreme Court did not have Jurisdiction to subject a

Layperson to Disciplinary Proceedings.

The Florida supreme court’s jurisdiction11 is limited “to regulate the admission

of persons to the practice of law and the discipline of persons admitted.” Art. V,

§15, Florida Constitution. At all relevant times I was not practicing law—

because I was not representing anyone inside or outside the court—, thus I was

II “‘Jurisdiction,’ in the strict meaning of the term, as applied to judicial of­

ficers and tribunals, means no more than the power lawfully existing to hear

and determine a cause... It does not depend upon the ultimate existence of a

good cause of action in the plaintiff, in the particular case before the court.”

Malone v. Meres, 91 Fla. 709,725 (Fla. 1926).

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not an attorney admitted to practice law by The Florida Bar.12,13,14,15

“Justices”, “judges”, and “attorneys” are mere titles and trades. They are not

12 At all relevant times, I did not proceed in the capacity of an attorney, not

even as a PROSE attorney. This fact has been acknowledged even by the

court that banned Citizen Jose from filing further appeals in it, except if I

proceeded in my capacity as an attorney. See Yeyille v. Speigel, 373 So. 3d

1238 (Fla. 3d DCA June 14 2023)(APPENDIX G). Jose Yeyille v. Glenn

Falk, Esq., 3D-2023-926 (August 2, 2023)(APPX. F). Jose Yeyille v. Justin

Cole Speigel, M.D., 3D-2023-2147 (April 3, 2024)(APPX. E). Jose Yeyille

v. Dinah Stein, Esq. et al., 3D24-418. (April 3,2024)(APPX. D). It did not

involve a “situation [1 involving the practice of law”, Florida Bar re

Amendments to Rules, 624 So. 2d 720,721 (Fla. 1993). Rules Regulating

The Florida Bar apply only to those “engage [d] in conduct in connection

with the practice of law.” Rule 4—8.4(d) (July 8, 2024).

13 The United States Supreme Court and the Florida supreme court agree on

what constitutes “the practice of law”. It defines it as the “preparation and

prosecution” and “conduct inevitably requir[ing] the practitioner to consider

and advise his clients.” Sperry v. Florida, 373 U.S. 379,383 (1963)[emphasis].

Indeed, when laypersons and nonlawyers have been prosecuted and punished

for engaging in the unauthorized practice of law, the crucial issue is whether

they had performed those services for money for the benefit and in representa­

tion of a third person: clients. The Florida Bar v. Furman, 451 So. 2d 808

(Fla. 1984).

14 “The Florida Supreme Court has identified ““acts commonly understood to

be the practice of law”” to include ““holding himself out as an attorney in

dealings with others; attempting to argue and advocate the merits of cases,

the ap- plicability of the law, evidentiary issues, liability issues, discovery

matters, and settlement matters with opposing counsel; and attempting to

analyze statutory and case law and to discuss it with clients and opposing

counsel.”” Yormak v. Yormak (In re Yormak), 640 B.R. 491, 503 (M.D. Fla.

2022)(quoting from The Florida Bar v. Nieman, 816 So. 2d 587, 594 (Fla.

2002) (emphasis added).

Page 20 of 32

always justices, judges, and attorneys. They are persons, too. They eat,

defecate, copulate, and die. They also sue and are sued for torts and breach of

contracts. They receive traffic tickets, fines, and criminal indictments, and

defend themselves in court in their capacities as common citizens; and they

file complaints and prosecute them for civil damages, and defend themselves

against civil lawsuits in their individual capacities; that is, as citizens; private

citizens, just like Citizen Jose.

““It would give public servants an unjustified preference over the public they

serve, if critics of official conduct did not have a fair equivalent of the immunity

granted to the officials themselves.”” Garrison v. Louisiana, 379 U.S. 64, 74

(1964)(quoting from New York Time, Co. v. Sullivan, 376 U.S. 254, 282-283

(1964)). In my capacity as common citizen—I am that critic.

III. The Florida Bar does not have subject matter jurisdiction to

harass and prosecute me—Citizen Jose.

“[T]he defense of subject-matter jurisdiction can be raised at any time. Fla.

15 Recently, in Warren v. DeSantis, 90 F.4th 1115 (Cir. January 11, 2024),

The U.S. Eleventh Circuit Court of Appeal ruled that a state attorney

(emphasis on attorney) “spoke as a private citizen” (ID. at 1132) (emphasis)

because he “did not sign the statements under his official duties”. (ID. at

1131). What’s in a signature? Everything. The Florida supreme court is

bound by this decision. U.S. Constitution, Article VI., Section 2. Supremacy

Clause. Howlett v. Rose, 496 U.S. 356,367 (1990).

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R. Civ. P. 1.140(h)(2).” Cunningham v. Standard Guar. Ins. Co., 630 So. 2d

179,181 (Fla. 1994). The Bar’s Complaint and the Report of “Referee” went

sideways as soon as they claimed that “Respondent is, and at all times

mentioned during this investigation was, a member of The Florida Bar, subject

to the jurisdiction and Disciplinary Rules of the Florida Supreme Court.”

At all relevant times. Citizen Jose was not and did not proceed, as a

member of the Florida Bar.

IV. VLTRA’VIRES: The Florida Bar (Florida Supreme Court), Bar

Counsels, Referee, and Justices harassed, prosecuted, and extorted me

beyond their authority.

“[J]udicial relief is available to one who has been injured by an act of a gov­

ernment official which is in excess of his express or implied powers.” Harmon

v. Brucker, 355 U.S. 579, 581-582 (1958) (citing Am. Sch. ofMagnetic

Healing v. McAnnulty, 187 U.S. 94,108 (1902)). “Courts must exercise their

independent judgment in deciding whether an agency has acted within its

statutory authority.” Loper Bright Enterprises, et al. v. Raimondo, Secretary

of Commerce, et al., No. 22-451, June 28, 2024, 603 U.S.(2024).

“[Questions of law that determine the constitutionality of an agency’s

decision fall ““outside the competence of administrative agencies" because

“the power of constitutional construction is inherent in, and exclusive to, the

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judiciary.”” Hensley v. State Commission on Judicial Conduct, et al., 692

S.W. 3d 184 (Tex. June 28, 2024), pgs. 27-28 (quoting from City ofDallas

v. Stewart, 361 S.W. 562, 578-579 (Tex. 2012)).16

The Florida supreme court refers to The Florida Bar as its “creation”, The

Florida Bar re Schwarz, 552 So. 2d 1094 (Fla. 1989); “an official arm of this

court.” RRTFB. Chapter 1. It is, in fact, an “administrative agency”. (See

16 Hensley resembles my case. In Hensley, a judge “authorized by virtue of

her judicial office to officiate at wedding ceremonies but not required to do so

as part of her judicial duties.. .announced that because of her religious beliefs

she would not perform weddings for same-sex couples.” (ID. at 3)(Emphasis).

Although she had the right to appeal it, she instead decided to sue “the Com­

mission and its members and officers for violating the Texas Religious Free­

dom Restoration Act (TRFRA)”*—Kindly, remark its identical counterpart in

Florida Anti-SLAPP Statute)*—’’and her right to freedom of speech under

Article I, Section 8 of the Texas Constitution (the Free Speech Clause)” IBID.

The trial court dismissed her claims for want of jurisdiction, barred them on

account of sovereign immunity, and held that the Commission’s officers

(commissioners) did not act in excess of their jurisdiction—ultra vires. The

court of appeals affirmed. The Texas supreme court reversed and held that

although the Commission itself has sovereign immunity neither the Commis­

sion nor its officers were entitled to it under the Texas Religious Freedom Act.

(See Florida Anti-SLAPP Statute). Regarding the VLTRA-VIRES issue, it

ordered the lower court to decide the constitutionality of the Commission’s

“investigation, Public Warning, and threat of future discipline” (ID. at page 8)

to determine whether the Commission and its officers acted beyond its juris­

diction because “questions of law that determine the constitutionality of an

agency’s decision fall ““outside the competence of administrative agencies””

because the power of constitutional construction is inherent in, and exclusive

to, the judiciary.”” ID. at 27. SVPRA.

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Florida supreme court website photo, p. 7 SVPRA.). “As an official agency of

the Supreme Court of Florida..The Florida Bar’s Regulation of Lawyer

Conduct’s website. In Liberty Counsel v. Florida Bar Board of Governors,

12 So. 3d 183 (2009), the Florida supreme court refers to the Bar as a

“corporation.. .a municipality, county, or town” (ID. at 191) subject to

VLTRA-VIRES review to determine whether The Florida Bar’s actions are

““unauthorized; beyond the scope of power allowed or granted by a corporate

charter or by law.”” (ID. at 191)(quoting from Black’s Law Dictionary 1559

(8th ed. 2004), and whether “the Bar.. .actfed] contrary to any of its rules or

policies, or rules promulgated by this Court.” (ID. at 192)[emphasis added].

““An agency action that is arbitrary stands outside the range of

discretion delegated to the agency for purposes of review.. .(allowing for

remand when an agency’s exercise of discretion, among other things, was

““[olutside the range of discretion delegated to the agency by law’ or

““loltherwise in violation of a constitutional or statutory provision””)””.

Floridians Against Inflated Rates, Inc. v. Clark, No. SC2021-1761, p. 23

(Fla. Sep.28,2023)(quoting from Int ’I Truck & Engine Corp. v. Cap. Truck,

Inc., 872 So.2d 372, 374 (Fla. 1st DCA 2004)(Emphasis added).

Therefore, because at all relevant times I was not practicing law, but

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proceeding as a common Citizen, The Florida Bar and the Florida supreme

court did not have jurisdiction to harass, prosecute, and extort common citizens

and lay-persons.

V. Absolute Litigation Privilege.

“The immunity afforded to statements made during the course of a judicial

proceeding extends not only to the parties in a proceeding but to judges,

witnesses, and counsel as well.” Levin, Middle-brooks v. U.S. Fire Ins. Co,

639 So.2d 606,608 (Fla. 1994)(Emphasis).17

17 Wielding Levin, the same Florida appellate court that referred me to the

Bar for disciplinary proceedings for criticizing the judiciary of the state of

Florida held that I could not sue two attorneys and their client for defamation

PER SE and ordinary defamation because they were entitled to immunity from

liability for these statements:

“It is likewise not the Plaintiffs first attempt to defraud the court

into believing that he is an unknowledgeable pro se plaintiff as he

is actually a barred attorney in the state of Florida parading under

the guise of a prose plaintiff nor is it the Plaintiffs first attempt to

defraud the court by claiming indigency by asserting that his

monthly bills total the exact amount as his monthly earnings in an

effort to skirt the reasonable fees required for filing a complaint.”

And “Acting under his own proclamations of indigency”. Yeyille v. Speigel,

3D23-2147 and Yeyille v. Stein, et aL, 3D24-418. The Florida supreme court

denied CERTIORARI for the first, Yeyille v. Speigel, SC2024-1672; and

denied discretionary for the latter because it did not only include an “elaborate

order”, but no order at all! Yeyille v. Stein, at aL, SC2024-1682.

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Therefore, The Florida Bar and the Florida state supreme court violated the

universal principle adopted by all jurisdictions in the United States—and all

civilized nations—(Louise Lark Hill. The Litigation Privilege: Its Place in

Contemporary Jurisprudence. Hofstra Law Review. Vol 44. Issue 2. (Dec. 1,

2015) by prosecuting me for defamation and libel on account of my statements

on public issues made exclusively in court filings.

VI. Right to Free Speech, Free Association, and to Petition the Govern­

ment (the Judiciary) for a Redress of Grievances. (Amendment I).

“Courts, too, are bound by the First Amendment/’ Citizens United v.

Fed. Election Comm’n, 558 U.S. 310,326 (2010). “[A] State may not, under

the guise of prohibiting professional misconduct, ignore constitutional rights.”

N.A.A.C.P. v. Button, 371 U.S. 415,439 (1963).

A. Free Speech: “(Disciplinary rules governing the legal profession

cannot punish activity protected by the First Amendment.” Gentile v. State

Bar ofNevada, 501 U.S. 1030,1054 (1991).18,19 In Landmark Communica­

tions, Inc. v. Virginia, 435 U.S. 829,842 (1978), this Court held “that injury

18 Florida Statute §454.11 “All attorneys shall be deemed officers of the court

for the administration of justice, and amenable to the rules and discipline of the

court in all matters of order or procedure not in conflict with the constitution

or laws of this state.” (Emphasis).

to official reputation [of judges] is an insufficient reason for repressing speech

that would otherwise be free.’ (quoting Sullivan at 272-273][Emphasis added],

19 “[Slpeech concerning public affairs is more than self-expression; it is the

essence of self-government. The First and Fourteenth Amendments embody our

‘profound national commitment to the principle that debate on public issues

should be uninhibited, robust, and wide-open, and that it may well include

vehement, caustic, and sometimes unpleasantly sharp attacks on government and

public officials.’” Garrison v. Louisiana, 379 U.S. 64,74 (1964)(quoting from

New York Times Co. v. Sullivan, 376 U.S. at 376 U.S. 270.” (Emphasis).

““[Slpeech on public issues occupies the highest rung of the hierarchy of First

Amendment values, and is entitled to special protection.”” Snyder v. Phelps, 562

U.S. 443,452 (2011) (quoting from Connick v. Myers, 461 U.S. 138, 145 (1983).

“Judges should be foremost in their vigilance to protect the freedom of others to

rebuke and castigate the bench and in their refusal to be influenced by unfair or

misinformed censure. Otherwise freedom may rest upon the precarious base of

judicial sensitiveness and caprice. And a chain reaction may be set up, resulting

in countless restrictions and limitations upon liberty.” Pennekamp v. Florida,

328 U.S. 331,370 (1946)(Emphasis). “Trial courts no doubt must be on guard

against confusing offenses to their sensibilities with obstruction to the ad­

ministration of justice.” Brown v. State, 356 U.S. 148,153 (1958)(Emphasis).

{See In re Little, 404 U.S. 553, 555 (1972). “[L]itigation [is] a vehicle for

effective political expression and association, as well as a means of communica­

ting useful information to the public.” In re Primus, 436 U.S. 412, 431 (1978).

“‘[S]peech concerning public affairs is more than self-expression; it is the

essence of self-government.’” United States v. Trump, 88 F.4th 990,1002 (D.

C. Cir. 2023)(quoting from Garrison v. Louisiana, 379 U.S. 64, 74-75 (1964).

In both his individual and his official capacity as President, Donald Trump has

called judges “fraud dressed up as a judge”. United States v. Trump, 88 F.4th

at 998; and “activists”, “rogue”, “unhinged”, and “crooked” U.S.A, v.

ChiefJudge George L. Russell,l:25-cv-Q2029 (Dist. Ct. Maryland June 24,

2025) (currently on appeal). Judge Thomas Cullen considered the Complaint

“not ordinary” (euphemism for “frivolous”) and condemned Trump for

“choos[ing] a different, and more confrontational path”, but still performed

his duty and judicial labor to issue a 39-page Order of August 26, 2025.

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and that “the institutional reputation of the courts, is entitled to no greater

weight in the constitutional scales.”

“The assumption that respect for the judiciary can be won by shielding

judges from published criticism wrongly appraises the character of

American public opinion.... [A]n enforced silence, however limited,

solely in the name of preserving the dignity of the bench, would probably

engender resentment, suspicion, and contempt much more than it would

enhance respect.” Bridges v. California, 314 U.S. 252,270-271 (1941).

Therefore, The Florida Bar and the Florida supreme court) violated

my right to free speech on public issues.

B. Free Association: Public sector unions which charge dues from non­

members violate their First Amendment rights to free speech and free

association. Janus v. American Fed’n of State, Cnty. & Mun. Emps., Council

31,138 S. Ct. 2448 (2018). ““Freedom of association.. .plainly presupposes a

freedom not to associate””, ID. at 2464 (quoting from Roberts v. United States

Jaycees, 468 U.S. 609, 623 (1984). ““[F]orced associations that burden

protected speech are impermissible””. IBID, (quoting from Pacific Gas & Elec.,

Co. v. Public Util. Comrn’n, 475 U.S. 1,12 (1986). I kindly ask this Court to

overturn Keller v. State Bar of CaL, 496 U.S. 1 (1990).

The Florida Bar (the Florida supreme court) forced me, Citizen Jose, to

associate with them. And Attorney Jose Yeyille contends that he cannot be

compelled to associate with them, and forced to pay dues to be harassed, pro-

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secuted, and extorted for exercising his right to Free Speech on public issues.

C. Petition the Government for a Redress of Grievances and to Access

the Courts20: By denying to me the right afforded to all laypersons and all

attorneys—even attorneys who are convicted criminals and attorneys who steal

from their clients, to contest the reports of Referees (APPS. C-D), the Florida

supreme court denied me my right to access the courts, to Petition the Govern­

ment (Judiciary) for a Redress of Grievances, and the Due Process and Equal

Protection of the Laws.

VII. NEMO IVDEX IN CAVSAM SVAM.

The law firm Greenberg Traurig, P.A. promotes, chooses, and owns the

judges of Florida third district court, justices of the Florida supreme court21,

and SCOTUS’ Justice Neil Gorsuch.21

20 “[T]he right to petition extends to all departments of the Government. The

right of access to the courts is indeed but one aspect of the right of petition.”

California Transport v. Trucking Unlimited, 404 U.S. 508, 510 (1972).

“[T]he Petition Clause protects the right of individuals to appeal to

courts.. .established by the government for resolution of legal disputes.

““[T]he right of access to courts for redress of wrongs is an aspect of the First

Amendment right to petition the government.”” Borough ofDuryea v.

Guarneri, 564 U.S. 379,387 (2011).

22 “Since 2014 Fred has served on and currently chairs the Florida

Supreme Court Judicial Nominating Commission (JNC), where five

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and SCOTUS’ Justice Neil Gorsuch.22

Greenberg Traurig, P.A.’s Fred Karlinsky publicly interviews the

justices of the Florida supreme court chosen by him.

Therefore, The Florida Bar and Florida supreme court are acting as judges

in their own case against me because they share an interest in muzzling and

prosecuting laypersons and attorneys who criticize the justices of the Florida

supreme court, and the judiciary of the state of Florida, and their benefactors23

of the seven current sitting Justices of the Florida Supreme Court have

been appointed during Fred’s tenure on the JNC.” Greenberg Traurig, P.A.

Website.

22 Greenberg Traurig, P.A.’s official Brian Duffy bought and owns Justice

Neil Gorsuch. Gorsuch ruled in Greenberg Traurig, P.A.’s favor “in eight out

of 12 cases” (“Gorsuch Reportedly Sold Property to Law Firm Executive After

Joining Supreme Court” by Katherine Hamilton. Forbes. April 25, 2023).

Heidi Przybyla. “Law Firm Head bought Gorsuch-ownedproperty: The

Supreme Courtjustice did not report the identity of the purchaser, whose

firm has had numerous cases before the court”. Politico (April 25, 2023).

Greenberg Traurig, P.A

23 Justices of the Florida supreme court owe their positions, salary, and status

to the law firm Greenberg Traurig, P.A. which openly and proudly broadcast

the fact that they choose them. “[N]o judge ““can be a judge in his own case

[or be] permitted to try cases where he has an interest in the outcome.”” Aetna

Life Insurance v. Lavoie, 475 U.S. 813 (1986)(quoting In re Murchison, 349

U.S. 133,136 (1955). Florida supreme court justices’ and The Florida Bar’s

pecuniary interest in harassing laypersons and attorneys who criticize the

judiciary and the law firm who owns them certainly are not miniscule. Tumey

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in violation of my Due Process right to a fair trial.

VIII. Florida Statute §768.295 (Anti-SLAPP).

Although §768.295 is a state statute, it explicitly incorporates the First

Amendment to the U.S. Constitution. “Whatever springes the state may set

for those who are endeavoring to assert rights that the state confers, the

assertion of federal rights, when plainly and reasonably made, is not to be

defeated under the name of local practice.” Davis v. Wechsler, 263 U.S. 22,

24 (1923).

Therefore, the Florida supreme court deceptively denied and refused to

rule on my Motion to Dismiss The Florida Bar’s case against me and the

Report of Referee pursuant to Florida Statute §768.295 (Anti-SLAPP)

(APPENDIX B) and denied my Motion for Rehearing and issued a final

judgment closing my case (APPENDIX A).

IX. Vagueness and Overbreadth of RRTFB.

The Florida Supreme Court and its agent The Florida Bar harassed,

prosecuted, and extorted me for the alleged violation of Rules Regulating The

v. Ohio, 273 U.S. 510, 523 (1927). 36% of The Florida Bar’s approved

general operating budget for the 2023-24 fiscal year came in part from

prosecution costs paid by disciplined lawyers. (The Florida Bar. What

we Do. Website).

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Florida Bar which are so incurably vague24 and overbroad25 that they can be,

and were indeed deceptively wielded as, criminal statutes to punish protected

conduct—criticizing the judiciary of the state of Florida in court filings —in

my capacity as common citizen—, and—speech on public issues in those

court filings in my capacity as common citizen—in violation of my First and

Fourteenth Amendments to the U.S. Constitution, respectively.

CONCLUSION

Kindly, grant my Petition for Writ of CERTIORARI.

March )>£, 2026CE

Jose Yeyille

Citizen Jose

PRO SE PETITIONER

5505 SW 135th Court

Miami, FL 33175

joseyeyille25@outlook.com

24 Their prohibitions are “not clearly defined” even for attorneys “and imper­

missibly delegates basic policy matters to.. .judges.. .for resolution on an ad hoc

and subjective basis, with the attendant dangers of arbitrary and discriminatory

application.” Grayned v. City ofRockford, 408 U.S. 104,108-109 (1972).

25 They “punish a ‘substantial’ amount of protected free speech, ‘judged in

relation to’ [their] ‘plainly legitimate sweep,”’ Virginia v. Hicks, 539 U.S. 113,

118-119 (2003). [Emphasis added].

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