Although neither party briefed the conflict of laws issue on appeal, both parties addressed the issue in motions filed with the trial court, and, thus, the record before us is sufficient to resolve this issue. In deciding conflict of laws issues, we are guided by the principles set forth in our previous decision in O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13 (1986). In O'Connor, we recognized that "[t]his court has traditionally adhered to the doctrine that the substantive rights and obligations arising out of a tort controversy are determined by the law of the place of injury, or lex loci delicti.

While Connecticut "traditionally adhered to the doctrine that the substantive rights and obligations arising out of a tort controversy are determined by the law of the place of injury, orlex loci delicti . . . in certain circumstances in which the traditional doctrine does not apply, the better rule is the analysis contained in the Restatement (Second) of the Conflict of Laws." Williams v. State Farm Mutual Automobile Insur. Co., 229 Conn. 359, 370 (1994); see O'Connor v. O'Connor, 201 Conn. 632 (1986). "Recently, courts applying Connecticut choice-of-law law have used the Restatement approach even where lex loci would lead to the same result."

Additionally, at least two other jurisdictions have also recognized that lex loci was an artificial product of the common law vested rights theory. See O'Connor v. O'Connor, 201 Conn. 632, 643, 519 A.2d 13, 18 (Conn. 1986); Gutierrez, 583 S.W.2d at 314-316. While we do not ignore our duty to ensure that our decisions are uniform and predictable, we also have a corresponding duty to recognize change and to participate in the growth of the law.

. See also Glenwood Systems, LLC v. Med–Pro Ideal Solutions, Inc., 438 Fed.Appx. 27, 29 (2d Cir.2011); Almonte v. New York Medical College, 851 F.Supp. 34, 39 (D.Conn.1994) (citing O'Connor v. O'Connor, 201 Conn. 632, 650, 519 A.2d 13 (1986) (quoting Restatement (Second) Conflicts of Laws § 145)). To determine the forum with the most significant relationship in the context of a tort case, the court considers “(a) the place where the injury occurred, (b) the place where the conduct causing the injury occurred, (c) the domicil, residence, nationality, place of incorporation and place of business of the parties, and (d) the place where the relationship, if any, between the parties is centered.” O'Connor, 201 Conn. at 652, 519 A.2d 13 (quoting Restatement (Second) Conflicts of Law § 145(2) and citing id., § 6).

Choice of law determinations can differ with respect to different elements of the case. Two conflict of law "tests" are utilized in Connecticut courts: the doctrine of " lex loci delicti" under which "the substantive rights and obligations arising out of a tort controversy are determined by the law of the place of injury," O'Connor v. O'Connor, 201 Conn. 632, 636, 519 A.2d 13, (1986), and "the principles of the Restatement Second [Conflict of Laws]," which the parties refer to as the "significant relationship test." Under Connecticut law, courts must "incorporate the guidelines of the Restatement as the governing principles for those cases in which application of the doctrine of lex loci would produce an arbitrary, irrational result." Id., at 650, 519 A.2d 13.

Connecticut's choice-of-law rules for tort claims, however, are less than clear. The Connecticut Supreme Court's watershed opinion in this area is O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13 (1986), in which the Court announced its willingness to depart from the doctrine of lex loci delicti: This court has traditionally adhered to the doctrine that the substantive rights and obligations arising out of a tort controversy are determined by the law of the place of injury, or lex loci delicti.

The court expressed its belief in that order that Massachusetts law governs this action. Id. (citing O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13, 22-26 (1986); Thomas v. Hanmer, 109 A.D.2d 80, 489 N.Y.S.2d 802, 803-07 (1985)). As explained at the hearing on June 7, 1990, the court has decided to reaffirm that belief and to conclude that plaintiffs' recovery under the Act does not preclude them from maintaining the instant action.

Connecticut's tort choice-of-law rules, which this Court must apply, Klaxon Co. v. Stentor Electric Manufacturing Co., Inc., 313 U.S. 487, 61 S.Ct. 1020, 85 L.Ed. 1477 (1941), formerly embodied a lex loci delicti approach. This doctrine was recently abandoned in favor of the choice of law rules promulgated in the Restatement, Second, Conflicts of Laws. O'Connor v. O'Connor, 201 Conn. 632, 648-50, 519 A.2d 13 (1986).          Under the Restatement approach adopted in O'Connor, the Court's choice of law analysis becomes a somewhat complex balancing task.

Rather, we must, as mandated by section 145(1), turn to the factors delineated in section 6 to determine which sovereign has the most significant contact. See O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13, 23 (1986) (to "resolve standoff" between interested states, court refers to relevant factors set forth in section 6(2)).O'Connor and the present case are controlled by section 6(2) because neither the Connecticut legislature nor the Florida legislature has, pursuant to section 6( 1), issued a statutory directive to guide conflicts disputes.

The plaintiffs argue that Connecticut law should apply under the more modern "significant relationship test," which calls for the application of the law of the jurisdiction that has the most significant relationship to the controversy in accordance with the principles of the Restatement (Second) of Conflict of Laws. See O'Connor v. O'Connor, 201 Conn. 632, 636 (1986). Federal courts apply the choice of law rules of the state in which they sit, and therefore Connecticut choice of law rules govern the dispute in the present case.