SUPREME COURT OPINION SUMMARY – Ludwig v. Dakota County

Cindy LUDWIG, Respondent, v. DAKOTA COUNTY, Self-Insured by SFM Risk Solutions, Relator.

SUPREME COURT – APRIL 22, 2026
No. A24-1989

In Ludwig v. Dakota County, the Minnesota Supreme Court addressed a narrow issue, whether an employee injured while transporting work equipment back to the office after an extended period of remote work, at her employer’s request, was entitled to workers’ compensation benefits under the “special errand” exception to the coming-and-going rule.

Cindy Ludwig had worked for Dakota County since 2002 in a clerical and customer service role. During the COVID-19 pandemic, the County required Ludwig to work remotely from home and she transported all of her County-owned equipment home. In 2021, the County directed Ludwig to return to in-person work under a new hybrid schedule. The morning of her return, Ludwig left home earlier than usual so she would have time to transport and set up her equipment before her 8:00 a.m. shift. While loading the equipment into her vehicle, she fell and injured her back.

Ludwig filed a workers’ compensation claim seeking wage loss and medical benefits. The compensation judge denied the claim, finding the injury occurred during her normal commute and therefore was barred by the coming-and-going rule. The Workers’ Compensation Court of Appeals (WCCA) reversed, concluding that the County implicitly requested Ludwig to return her work equipment before the start of her shift, making the trip a directive and a “special errand.” Dakota County appealed to the Minnesota Supreme Court.

The Supreme Court affirmed the WCCA and held that Ludwig’s injury was compensable under the special-errand exception. The Court reiterated that although injuries sustained while traveling to and from work are generally not compensable, an exception applies when an employee is performing a special task or mission for the employer outside the normal course of employment. The Court relied on longstanding Minnesota precedent holding that the exception applies when: (1) the employer expressly or impliedly requests a task outside normal working hours; (2) the trip is an integral part of the service performed; and (3) the task is special or non-recurring during the normal hours of employment.

Applying those factors, the Court concluded that Dakota County implicitly required Ludwig to bring the equipment necessary to perform her job back to the office before her shift began. The transportation of the equipment was integral to her ability to work, and the task was unique because it occurred during a one-time transition from pandemic-related remote work to a new hybrid schedule. The Court distinguished prior cases involving ordinary commutes with personal work tools, emphasizing that Ludwig’s circumstances involved employer-owned equipment and a specific directive tied to returning to in-office work.

Although the Court described the facts as unique, the decision is significant because it demonstrates that the “special errand” exception may apply when an employee is directed to transport work equipment outside the scope of a routine commute as part of a return to in-person or hybrid work.

Summary prepared by Attorney Alena Nesvetaylov