A former financial consultant has accused a major insurance company of discrimination and retaliation after allegedly being terminated for practicing Indigenous religious beliefs, according to a recent federal court filing. The complaint was filed by Apelete Houngbo in the United States District Court for the Northern District of Illinois on March 26, 2026, naming Allstate Insurance Company as the defendant.
According to the complaint, Houngbo claims that Allstate Insurance Company engaged in unlawful discrimination under Title VII of the Civil Rights Act of 1964 by failing to accommodate his sincerely held Indigenous religious beliefs. The suit also alleges violations of the Fair Labor Standards Act for not paying minimum wage for all hours worked and breaches of the Illinois Wage Payment and Collection Act related to unpaid final compensation.
The document states that Houngbo was employed as a Financial Consultant from approximately June 12, 2023 until his termination on or about June 23, 2025. His responsibilities included providing financial consulting services to clients and participating in meetings with both clients and internal teams. According to Houngbo, these duties did not require visual presentation or camera use during virtual meetings.
Houngbo identifies as a follower of Indigenous religious beliefs which prohibit appearing on camera during meetings and participating in activities involving alcohol. He asserts that he informed management and Human Resources at Allstate about his need for religious accommodation regarding these practices. Despite this disclosure, Houngbo claims that his reluctance to appear on camera was viewed negatively by management and impacted his performance evaluations.
The complaint details an incident around April 4, 2025 when Houngbo contacted Human Resources after receiving what he describes as a defamatory report accusing him of being uncooperative. On that date, he submitted a written request for religious accommodation asking Allstate to respect his beliefs and cease negative evaluations based on those beliefs. “Despite Plaintiff’s disclosure and formal request for religious accommodation,” the complaint states, “Defendant failed to provide a reasonable accommodation and failed to take corrective action regarding the negative performance evaluations tied to Plaintiff’s religious practices.”
On May 30, 2025, Houngbo was placed on a Performance Improvement Plan citing alleged underperformance as well as his use of vacation time and refusal to attend company events involving alcohol—actions he says were consistent with his religious convictions. He continued communicating with Human Resources but alleges that no meaningful response or modification of working conditions occurred.
The filing asserts that Allstate subjected Houngbo to heightened scrutiny, discipline, adverse treatment because of his religion, and retaliation for requesting accommodation. It further claims that Allstate failed to conduct an objective investigation into complaints about religion-based discrimination or harassment: “Defendant’s failure to act allowed the discriminatory and retaliatory conduct to continue and materially contributed to a hostile work environment based on religion.” Ultimately, Houngbo contends there is compelling evidence he was terminated due to his religion.
In addition to discrimination claims under Title VII—including failure to accommodate religious belief or practice—the lawsuit accuses Allstate of violating wage laws by failing to compensate him fully for all hours worked during his final period of employment. Specifically, it alleges non-payment for accrued vacation hours and issuance of only a minimal deposit rather than full wages owed: “Plaintiff received a minimal deposit which did not reflect the appropriate amount owed for his final weeks worked nor did it contain his vacation balance.” The suit states this resulted in an effective rate below federal minimum wage requirements.
Houngbo seeks several forms of relief from the court including back pay with interest; payment of interest on all back pay recoverable; front pay; compensatory and punitive damages; reasonable attorney’s fees; pre-judgment interest if applicable; and any other relief deemed just by the court.
The case is identified as Case: 1:26-cv-03340. Legal representation for Apelete Houngbo is provided by Travis P. Lampert of Atlas Law Center Ltd., located in Lombard, Illinois.
Source: 126cv03340_Apelete_Houngbo_v_Allstate_InsuranceComplaint_Northern_District_of_Illinois.pdf