## Facts

- Roseann O’Connor (plaintiff) and Brian O’Connor (defendant) were both domiciliaries of Connecticut.
- They took a one-day pleasure trip that began in Connecticut and was intended to end in Vermont.
- While traveling through Quebec, Canada, the defendant’s vehicle was involved in an accident that seriously injured the plaintiff, the sole passenger.
- The plaintiff received initial treatment in Quebec and then returned to Connecticut, where she continued treatment and experienced the long-term effects of her injuries.
- Neither party was a resident of Quebec, and the vehicle was neither registered nor insured in Quebec.
- The plaintiff sued in Connecticut in tort; the defendant argued Quebec’s Automobile Insurance Act (a no-fault scheme) applied and barred the claim.

## Issues

1. In a tort action between two Connecticut domiciliaries arising from an accident in Quebec, whether Connecticut choice-of-law rules require application of Quebec law (lex loci delicti) or Connecticut law under a “most significant relationship” analysis.
2. Whether Quebec’s no-fault statute bars the plaintiff’s Connecticut tort action against the defendant.

## Decision

- The Connecticut Supreme Court reversed the Appellate Court and rejected a rigid lex loci delicti approach on these facts.
- The court held Connecticut law governs because Connecticut had the most significant relationship to the occurrence and the parties.
- The court concluded Quebec’s no-fault scheme did not bar the plaintiff’s tort action in Connecticut.
- The case was remanded for further proceedings applying Connecticut law.

## Legal Principles

- Tort choice-of-law determinations may apply the Restatement (Second) of Conflict of Laws “most significant relationship” test rather than mechanically applying the law of the place of injury.
- Restatement factors include: place of injury; place of conduct causing injury; parties’ domiciles/residences; and where the parties’ relationship is centered, evaluated in light of the policies and interests of the involved jurisdictions.
- When the place of injury is fortuitous and the foreign jurisdiction has minimal regulatory interest (e.g., neither party nor vehicle is connected to that jurisdiction), its law may yield to the forum state’s law where both parties are domiciliaries and the continuing consequences are centered.
- Choice-of-law analysis considers fairness, predictability, and the parties’ reasonable expectations regarding which legal regime will govern their rights and liabilities.

## Conclusion

Connecticut law governed a tort suit between Connecticut domiciliaries injured in an accident occurring in Quebec because Quebec’s connection was largely incidental and its no-fault policy was not meaningfully served, while Connecticut had the dominant interest in regulating compensation and liability for its residents.


O’Connor v. O’Connor, 201 Conn. 632, 519 A.2d 13 (1986)