Your Complainant is an Investigator for the Anoka County Sheriff’s Office and in such capacity makes this Complaint based upon the reports of Deputy Justin Miller, whom your Complainant believes to be truthful and reliable. On October 20, 2025, at approximately 9:02 A.M., Deputy Justin Miller of the Anoka County Sheriff’s Office was on duty and responded to a two-vehicle motor vehicle accident occurring at Hanson Boulevard NW and Bluebird Street NW, in the City of Andover, County of Anoka, State of Minnesota.
Upon arrival, Deputy Miller first spoke with the driver of the black Dodge Dakota, Minnesota license plate [PLATE REDACTED]. The driver identified as ROBYS MORENO, [DOB redacted], subsequently the defendant herein, stated that he was southbound on Hanson Boulevard in the left turn lane at Bluebird Street NW. The defendant stated that he was starting to make its turn to peek around a vehicle that was in the northbound left turn lane but was unable to see the approaching vehicle in the straight northbound lane of travel.
The defendant stated that the two vehicles struck head-on. Deputy Miller spoke with the driver of the other vehicle involved in the accident, a Honda HRV, Minnesota license plate [PLATE REDACTED]. The driver stated that she had been traveling northbound on Hanson Boulevard NW and was unable to see the defendant pull out in front of her and unable to avoid the collision. Deputy Miller observed both vehicles sustained severe front-end damage. Deputy Miller conducted a computer check on the defendant and learned the defendant’s driver’s license status was canceled as inimical to public safety.
The defendant stated that he was aware that his driver’s license was not valid and that he should not be driving. This Complaint is further based upon a report from the Minnesota Department of Public Safety indicating the defendant’s driver’s license status was canceled as inimical to public safety and not reinstated. The above facts constitute the Complainant’s basis for believing that the above-named defendant, on the 20th day of October 2025, in the City of Andover, County of Anoka, State of Minnesota, committed the above-named offense(s).
