Minnesota court: Hybrid worker’s injury carrying equipment compensable

A county employee who injured her back while loading work equipment into her vehicle as she returned to the office after pandemic remote work is entitled to workers compensation benefits, the Minnesota Supreme Court ruled Wednesday.

According to Cindy Ludwig vs. Dakota County, Self-Insured by SFM Risk SolutionsCindy Ludwig, a Dakota County clerical and customer service employee, had worked from home since March 2020 under a county directive. When the county ordered her to return to its Hastings office in September 2021 to begin a hybrid schedule, she packed county-owned equipment, including monitors, cords, a docking station, keyboard, headset and binders, according to the ruling.

On Sept. 8, 2021, she left earlier than usual so she could set up the equipment before her 8 a.m. shift. While loading a bin into her van, she fell and injured her back.

The court affirmed a Workers’ Compensation Court of Appeals ruling that Ms. Ludwig’s injury fell under the “special errand” exception to the general rule barring compensation for injuries sustained during a commute.

A compensation judge had previously denied benefits, finding the injury occurred during her commute. The WCCA reversed, finding the county’s return-to-office directive included an implied request that Ms. Ludwig bring back her equipment before her shift began.

The Supreme Court agreed, holding the WCCA did not improperly make a factual finding and did not err in applying the special-errand exception. The court said Ms. Ludwig’s trip was not part of a routine hybrid commute but an initial return to the office after a prolonged work-from-home order, and that transporting the equipment was necessary for her to resume work in person.

In a concurrence, on justice said the case presented a missed opportunity to clarify how the special-errand exception applies in modern hybrid work arrangements, warning that routine transport of laptops or other equipment should not automatically make a commute compensable.