A sworn officer of the St. Cloud Police Department duly states the following facts establish PROBABLE CAUSE: On or about April 19, 2025, at approximately 10:13AM, Officer Brady Goebel, while on routine patrol, initiated a traffic stop on a 2009 Dodge Avenger bearing Minnesota license plate [PLATE REDACTED] at Southtown Liquor, 930 9th Avenue South, City of St. Cloud, County of Stearns, State of Minnesota. Officer Goebel, through previous contacts with the vehicle, knew its registered owner, and secondary driver, to have [DL# REDACTED] of canceled-inimical to public safety.
Officer Goebel made contact with the driver and immediately identified him as the known secondary driver of the vehicle, Demetrius Elijah McAllister, [DOB REDACTED], the Defendant herein. The Defendant's [DL# REDACTED] is canceled-inimical to public safety as of July 25, 2024, and has not been reinstated as of April 19, 2025. The Defendant knew, or should have reasonably known, of his [DL# REDACTED]. Complainant has reason to believe and does believe that all above information is true and correct.
The above facts constitute the complainant's basis for believing that the above-named defendant, on or about April 19, 2025, in the City of St. Cloud, County of Stearns, State of Minnesota, committed the described offense herein.