Supreme Court Digest: April 22, 2026

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Civil

Workers’ Compensation

Special Errands

This case was about whether respondent-employee’s injury—sustained while transporting equipment back to her office to resume working in-person, at her employer’s request, after working remotely from home—was compensable under the Workers’ Compensation Act. Generally, an employee’s injury that occurs while commuting to and from work is not compensable. But respondent argued that because she was injured while on a “special errand” for her employer, relator-county, her injury is compensable under the special-errand exception to this general rule. The compensation judge concluded that the special-errand exception did not apply because respondent’s injury occurred when she returned “her equipment to the job site” as “part of her commute.” The Workers’ Compensation Court of Appeals (WCCA) reversed, finding that the county’s request that respondent return to the office to begin a new hybrid schedule included an implied request that respondent return her office equipment before her regular shift, thus qualifying respondent’s return-to-office trip as a special errand.

The Supreme Court held that (1) the WCCA did not make an impermissible factual finding when it applied the special-errand exception because the finding and its supporting inference were not manifestly contrary to the evidence; and (2) the WCCA did not err as a matter of law by concluding that the employee’s injury was compensable under the special-errand exception to the general rule that an employee’s injury that occurs while commuting to and from work is not compensable. Affirmed.

A24-1989 Ludwig v. Dakota County (Workers’ Compensation Court of Appeals)