Commonwealth v. O'Leary

**67 The defendant, Richard O'Leary, asks this court to determine whether the Commonwealth met its burden of proving compliance with the citation requirement of G. L. c. 90C, § 2, which mandates the issuance of a traffic citation "at the time and place of the violation," despite the fact that a State police trooper did not issue a traffic citation at the scene of the violation or at the hospital following the interviews he conducted. Instead, before issuing the citation, the trooper submitted an accident report to his supervisor for approval, which the trooper received nine days later.…