Todd A Anderson

Complaint template prepared from a public-record review by drtrustmebro.com. The complaint you submit is your own; review and edit every statement before signing. This template is intended for residents or patients of Minnesota. It is not legal advice.

In the Matter of:
Todd A Anderson
License No. [LICENSE NUMBER, IF KNOWN]
231 Main Street NW, Elk River, Minnesota, 55330
NPI (public registry): 1134662133

I. INTRODUCTION

Complainant respectfully submits this complaint to the MINNESOTA BOARD OF CHIROPRACTIC EXAMINERS requesting formal investigation and regulatory review concerning Todd A Anderson (the Respondent), identified in the attached public materials.

The public materials reviewed appear to present representations concerning the identification and management of health conditions, including Autoimmunity, Thyroid Support, Hormone Balance, Reverse autoimmune conditions, Leaky gut causes chronic disease, and Functional Medicine for Autoimmunity, that may extend beyond the DC scope in Minnesota.

This complaint is based exclusively upon publicly available materials and does not rely upon confidential patient records, privileged communications, or non-public investigative information. The factual observations herein were assembled from an automated public-record review of the Respondent's public website and public registry records, and were reviewed and adopted by the Complainant. All observations are potential, unverified signals from public records; the Board is the sole finder of fact.

The principal public materials reviewed include https://momentumhealthwellnessmn.com/, https://us.fullscript.com/welcome/dranderson, https://momentumhealthwellnessmn.com/labs-supplements.html and the public registry and license verification sources listed in the exhibit index below.

II. STATEMENT OF FACTS

A. Scope of Practice Concerns

Public content appears to address Autoimmunity, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Thyroid Support, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Hormone Balance, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Reverse autoimmune conditions, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Leaky gut causes chronic disease, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Functional Medicine for Autoimmunity, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Hormone Optimization (TRT/Estrogen), which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Leaky Gut / SIBO Protocols, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Digestion & Gut Health, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Optimize hormones (TRT/peptides implied), which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Functional Medicine, which the cited rule text suggests may fall outside the DC scope in Minnesota. Public content appears to address Blood Work Analysis, which the cited rule text suggests may fall outside the DC scope in Minnesota.

III. AREAS OF CONCERN

COUNT I: PRACTICE BEYOND THE SCOPE OF CHIROPRACTIC

Cited authority: Minn. Stat. Sections 148.01 to 148.108.

The public materials described in the Statement of Facts above appear to address Autoimmunity, Thyroid Support, Hormone Balance, Reverse autoimmune conditions, Leaky gut causes chronic disease, Functional Medicine for Autoimmunity, Hormone Optimization (TRT/Estrogen), Leaky Gut / SIBO Protocols, Digestion & Gut Health, Optimize hormones (TRT/peptides implied), Functional Medicine, and Blood Work Analysis, which the cited rule text suggests may fall outside the DC scope.

The conduct described above raises substantial concerns under Minn. Stat. Sections 148.01 to 148.108 and warrants Board investigation.

COUNT II: DIAGNOSTIC TESTING AND MEDICAL-STYLE EVALUATION

Cited authority: Minn. Stat. Section 148.01.

The public materials described above appear to present condition-specific frameworks, laboratory-testing guidance, and treatment protocols directed at systemic conditions, rather than services grounded in the licensed scope.

The conduct described above raises substantial concerns under Minn. Stat. Section 148.01 and warrants Board investigation.

COUNT III: GROUNDS FOR DISCIPLINARY ACTION

Cited authority: Minn. Stat. Section 148.10.

The conduct described above raises substantial concerns under Minn. Stat. Section 148.10 and warrants Board investigation.

IV. RELIEF REQUESTED

A. Formal investigation of the conduct described herein, including review of the Respondent's public advertising, website representations, consultation materials, and commercial structures.

B. A determination by the Board of whether the conduct described herein is consistent with the statutes and rules cited above.

C. Such disciplinary action as the Board deems appropriate based on its own investigation and findings, up to the maximum authorized for any violation the Board finds.

D. Corrective relief, where the Board deems appropriate, including requiring the Respondent to correct or remove the specific public representations described above and, if the conduct continues, seeking injunctive relief through a court of competent jurisdiction.

E. To the extent within the Board's authority, review of the revenues derived from the consultations, care plans, and product sales described above, and consideration of restitution for consumers who relied on the representations to their financial or physical detriment.

F. Such other and further relief as the Board deems just and proper to protect the public.

Respectfully submitted,

[YOUR NAME]

[YOUR MAILING ADDRESS]

[YOUR EMAIL AND PHONE]

[DATE]

EDIT BEFORE SENDING

1. Confirm the license number using the license lookup in Exhibit A and fill it in on page 1.
2. Replace every bracketed placeholder with your own information, or delete sections that do not apply.
3. Print and attach dated captures of each exhibit page listed in the exhibit index.
4. Review every factual statement yourself before signing; submit only what you can stand behind.
5. Check the board's current submission rules (online portal, mail, or fax) before sending.

EXHIBIT INDEX