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."

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.

. 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).

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.

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.

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.

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.