Cindy Ludwig v. Dakota County, Self-Insured by SFM Risk Solutions

Summary

The Minnesota Supreme Court affirmed the Workers’ Compensation Court of Appeals’ determination that Cindy Ludwig’s injury was compensable under the special-errand exception to the coming-and-going rule. The court held that the WCCA did not make an impermissible factual finding by inferring that Dakota County implicitly requested Ludwig to return her work equipment before her regular shift, and that the injury occurred while she was performing a special errand for the employer. Justice McKeig concurred separately, questioning aspects of the WCCA’s analysis and advocating clarification of the exception in hybrid-work cases.

Holdings

1. The WCCA did not make an impermissible factual finding when it concluded that the County’s return-to-office directive included an implied request that Ludwig return her work equipment before her regular shift.
2. Ludwig’s injury was compensable under the special-errand exception because she was injured while returning employer-owned equipment to the office for the first time after a prolonged work-from-home period, at the County’s request, before beginning a new hybrid schedule.

Questions Presented

1. Whether the WCCA made an impermissible factual finding by concluding that the County’s return-to-office directive implicitly required Ludwig to return her work equipment before her regular shift.
2. Whether Ludwig’s injury was compensable under the special-errand exception to the general rule that injuries sustained while commuting to or from work are not compensable.

Disposition

affirmed