Commonwealth v. Martinez, 32 N.E.3d 1283

Early morning collision: Martinez's station wagon sideswiped a parked car with Cordiero inside; Cordiero could not exit driver side due to damage.
Martinez and a passenger exited; Martinez's sister (who had been following) took Martinez's station wagon and drove off, later returning about 15 minutes later.
Cordiero asked for Martinez's license and registration; Martinez said they were in the station wagon that had left and that the wagon would return; Martinez asked Cordiero not to call police.
Martinez's sister returned with Martinez's license and registration and urged resolving the matter without police; Cordiero refused the offered documents and waited for police, who later used the plate number to locate Martinez.
No effective transfer of identifying information to Cordiero or police occurred at the scene; Martinez was charged and convicted under G. L. c. 90, § 24(2)(a) for leaving the scene without making known name, address, and vehicle registration number.
Trial court denied a motion for required finding of not guilty; Martinez appealed, arguing her offer of information satisfied the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant satisfied § 24(2)(a) by offering information	Commonwealth: defendant did not make identifying info known to the other party or police	Martinez: offering her license/registration (or paper) to Cordiero satisfied the statutory duty	Held: Offering is not enough; information must be made known — Martinez failed to make it known and left the scene
Whether recipient's refusal to accept info excuses defendant	Commonwealth: refusal does not absolve defendant from statutory duty	Martinez: Cordiero's refusal meant defendant had tendered info and thus complied	Held: Recipient's refusal does not relieve defendant of obligation to make information known
Whether oral offer can suffice	Commonwealth: identification must be explicit and made known; oral disclosure can suffice if it results in information being known	Martinez: relied on attempt to provide documents/paper	Held: Oral disclosure may suffice in principle, but here no effective oral disclosure or transfer occurred
Whether prosecutor's closing remarks were improper	Commonwealth: remarks responded to defense argument	Martinez: closing was improper and prejudicial	Held: No reversible error; remarks were responsive and jury instructed accordingly

Commonwealth v. Platt, 440 Mass. 396 (2003) (elements of § 24(2)(a) and sufficiency review)
Commonwealth v. Horsfall, 213 Mass. 232 (1913) (statute requires immediate tendering of explicit identifying information)
Commonwealth v. Kraatz, 2 Mass. App. Ct. 196 (1974) (Legislature imposed strict liability for incorrect belief of sufficient disclosure)
Commonwealth v. Joyce, 326 Mass. 751 (1951) (dicta that oral disclosure can constitute making information known)
Commonwealth v. Smith, 450 Mass. 395 (2008) (limits on prosecutorial remarks in closing)
Commonwealth v. Andrade, 468 Mass. 543 (2014) (presumption that juries follow judicial instructions)