Prepared by SFM’s in-house legal team
As more workplaces shift into hybrid schedules, courts are beginning to confront a new question: When employees carry work equipment between home and office, what happens if they get hurt in the process?
The Minnesota Supreme Court recently weighed in on the matter in Ludwig v. Dakota County (April 22, 2026), offering important guidance for employers and employees navigating the realities of post-pandemic work.
The court affirmed that an employee injured while bringing her work equipment back to the office — at her employer’s direction — was entitled to workers’ compensation benefits.
The case at hand
After working remotely during the pandemic, Cindy Ludwig was told to return to the office to begin a new hybrid schedule. She had taken home all of her employer-owned equipment: laptop, monitors, docking station, cords, headset, binders and even her office chair.
To be ready for her 8 a.m. shift on her first day back in the office, she left home earlier than usual so she could set up her workstation before the workday began. While in the process of lifting a large bin of equipment into her car, she fell and injured her back. The injury happened while she was loading work equipment, but she testified that she did not know exactly why she fell.
The Minnesota Workers’ Compensation Court of Appeals previously held that Ludwig was in the course and scope of employment, despite the fact that the injury happened before she arrived at the workplace.
Injuries that happen before an employee reaches the workplace are generally not compensable. However, the Court of Appeals found that Ludwig in this case was engaged in a “special errand,” and confirmed that the injury does not have to definitively arise from the employment in order for it to be compensable during a special errand.
Supreme Court’s decision
The Supreme Court agreed with the Workers’ Compensation Court of Appeals that this wasn’t an ordinary commute.
Because Ludwig needed to return her equipment before her shift — and because the employer had directed her to resume in-person work on a specific date — the court concluded she was performing a “special errand” for her employer. That exception makes injuries compensable even when they occur off the employer’s premises.
The key question was not why the employee fell but instead what she was doing at the time she fell. The decision turned on whether the employee was on a special errand at the time of the injury. In finding a compensable “special errand” injury, the court emphasized that this was a one-time, employer-driven task tied to the transition back to the office. It wasn’t part of Ludwig’s normal routine, and there was no evidence she could have simply used backup equipment at the office.
Other considerations
A concurring justice agreed with the outcome but warned that hybrid work shouldn’t automatically turn every laptop-carrying commute into a compensable special errand. The opinion signals that courts will need to draw careful lines as hybrid work becomes more common.
For Minnesota employers, the takeaway is that when employers require employees to bring essential equipment from home to the office — especially after long periods of remote work — injuries that occur during that transport may be covered by workers’ compensation. Minnesota law generally does not cover injuries that occur during a routine commute, and whether the special errand exception applies is always a fact-specific inquiry.
Read the full text of the Minnesota Supreme Court’s Ludwig decision here.
This is not intended to serve as legal advice for individual fact-specific legal cases or as a legal basis for your employment practices.
