When the interested states' laws relevant to the operative facts produce the same outcome, there is no real conflict between the jurisdictions. O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13, 25 n. 18 (1986). When no conflict exists for a certain issue, the court may decide that issue using the law that is common to all of the affected jurisdictions.

When the interested states' laws relevant to the operative facts produce the same outcome, there is no real conflict between the jurisdictions. O'Connor v. O'Connor, 519 A.2d 13, 25 n. 18 (Conn. 1986). When no conflict exists for a certain issue, the court may decide that issue using the law that is common to all of the affected jurisdictions.

As discussed infra, however, application of the "most significant relationship" standard to this case produces the same end result as would occur if New York's conflict rules were so applied. See O'Connor v. O'Connor, 201 Conn. 632, 649-50 n. 12, 519 A.2d 13, 21-22 n. 12 (1986). 1 Restatement (Second) Conflict of Laws § 187 comment h (1971 and Supp. 1985-86); see also SCA Serv., Inc., 599 F.2d at 180; Sullivan v. Savin Business Machines Corp., 560 F.Supp. 938, 939 (N.D.Ind. 1983); LaBeach v. Beatrice Foods Co., 461 F.Supp. 152, 156 (S.D.N.Y. 1978).

Connecticut choice of law principles “traditionally [adhere] 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.” O'Connor v. O'Connor, 201 Conn. 632, 637, 519 A.2d 13 (1986). This doctrine was slightly modified in O'Connor, which holds that when the “application of the doctrine of lex loci delicti would produce an arbitrary, irrational result” we should turn to and “incorporate the guidelines of the Restatement [ (Second) of Conflict of Laws] as the governing principles....” Id., at 650, 519 A.2d 13.

Id., at 214, 78 A.3d 167. In conducting the choice of law analysis in the present case, both the trial court and the Appellate Court, citing O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13 (1986), first applied the doctrine of lex loci delicti—the place of injury—before proceeding to the most significant relationship test set forth in §§ 6 (2) and 145 of the Restatement (Second) of Conflict of Laws. See Western Dermatology Consultants, P.C. v. VitalWorks, Inc., supra, 146 Conn.App. at 203–206, 78 A.3d 167. As we stated in Jaiguay, however, "we have moved away from the place of the injury rule for tort actions and adopted the most significant relationship test found in §§ 6 and 145 of the Restatement (Second) of Conflict of Laws." Jaiguay v. Vasquez, supra, 287 Conn. at 349, 948 A.2d 955.

E.g., Gibson v. Fullin, 172 Conn. 407, 411, 374 A.2d 1061, 1064 (1977). 201 Conn. 632, 519 A.2d 13 (1986).Id. at 648, 519 A.2d at 21.

See Dugan v. Mobile Med. Testing Servs., Inc., 265 Conn. 791, 830 A.2d 752, 758 (2006). If so, then “the doctrine that the substantive rights and obligations arising out of a tort controversy are determined by the law of the place of injury,” also known as “ lex loci delicti ”, typically applies. O'Connor v. O'Connor, 201 Conn. 632, 519 A.2d 13, 15 (1986). However, the Connecticut Supreme Court has held that lex loci delicti does not apply to a tort claim when the application would undermine expectations of the parties or an important state policy, when the application would produce an arbitrary and irrational result, or where “reason and justice” counsel for the application of a different principle.

Traditionally, Connecticut courts applied the common law doctrine of lex loci delicti, that " 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, 637, 519 A.2d 13 (1986). Where " application of the doctrine of lex loci would produce an arbitrary, irrational result," Connecticut courts look to the Restatement instead.

Under that doctrine, in this action the state suffering the economic impact of CRRA's $220 million loan to Enron would be Connecticut and its law would govern the substantive rights and obligations of the parties to the litigation. O'Connor v. O'Connor, 201 Conn. 621, 637, 519 A.2d 13, 15 (1986). Subsequently in 1986 Connecticut modified that approach in tort actions where "application of the doctrine of lex loci would produce an arbitrary, irrational result" to embrace the "most significant relationship" analysis of the Restatement (Second) of Conflict of Laws §§ 6 and 145(1) and (2) (1971) because that test "represent[ed] the most comprehensive and equitably balanced approach to the conflict of laws."

However, where a lex loci analysis "would produce arbitrary, irrational results," the approach set forth in the Restatement (Second) Conflict of Laws will be applied. See id. (citing O'Connor v. O'Connor, 201 Conn. 632, 650, 519 A.2d 13, 22 (1986) (internal quotation marks omitted)). In the pending motions, neither plaintiff nor defendants claim a conflict of law.