In Sturiano v. Brooks, 523 So. 2d 1126 (Fla. 1988), the Court considered--and rejected--the significant relationships test. Id. at 1128-29. In that case, the Court answered a certified question asking whether the lex loci rule governed the "rights and liabilities of the parties in determining the applicable law on an issue of insurance coverage." Id. The Court discussed the significant relationships test, which requires consideration of various contacts between the contract and the states involved--such as the place of contracting and the place of performance--and weighing them to determine the state with the "most significant relationship to the transaction and the parties." Id. at 1129 (quoting Restatement (Second) of Conflict of Laws 188 (1971)). The Court acknowledged that "lex loci contractus is an inflexible rule," but concluded that "this inflexibility is necessary to ensure stability in contract arrangements." Id. The Court reasoned that "when parties come to terms in an agreement, they do so with the implied acknowledgment that the laws of that jurisdiction will control absent some provision to the contrary." Id. The Court concluded that to abandon this principle and permit a party to change or modify contract terms by moving to another state would unnecessarily disrupt the stability of contracts. Id. The Court explained the purpose behind the rule as follows: "In the case of an insurance contract, the parties enter into that contract with the acknowledgment that the laws of that jurisdiction control their actions. In essence, that jurisdiction's laws are incorporated by implication into the agreement. The parties to this contract did not bargain for Florida or any other state's laws to control. We must presume that the parties did bargain for, or at least expected, New York law to apply." Id. at 1130.