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Ludwig v. Dakota County - Special-Errand Exception to Workers' Comp Affirmed

The Minnesota Supreme Court affirmed the Workers' Compensation Court of Appeals in Ludwig v. Dakota County, holding that an employee's injury sustained while loading work equipment into her vehicle to return to a hybrid in-office schedule is compensable under the special-errand exception to the general rule excluding commuting injuries. The court found that Dakota County's directive to return to the office implicitly required employees to bring their equipment back before the shift began, transforming the return trip from a non-compensable commute into a compensable special errand. The decision reverses the compensation judge's reliance on Thompson v. Minnesota Trial Courts, distinguishing it because Ludwig had no backup equipment available at the office while Thompson's employee did.