Geoffrey S. Wagner

Wagner and Levitsky Win in Court of Appeals

On August 26, 2021, the Michigan Court of Appeals issued a published decision in Cramer v Transitional Health Services of Wayne (Dkt. No. 347806). In Cramer, the Court of Appeals ruled in favor of our client, Transitional Health, and affirmed an earlier decision from the Michigan Compensation Appellate Commission. In so doing, the Court rejected Plaintiff-Appellant’s request to: (a) modify the causation standard for mental disability claims under the Michigan Workers’ Compensation Act (“WCA”); and (b) return to the lax and subjective “honest belief of disability” standard, which existed prior to the Legislature’s 1980 overhaul of the WCA. This is a big win for GMH and, moreover, for employers throughout the State of Michigan. Congratulations, Geoff and Adam!

Geoff Wagner is an equity partner with GMH and the Chair of its Appellate Group. He specializes in appellate practice, commercial litigation, employment law, personal injury and family law. Geoff has an AV Peer Review Rating from Martindale-Hubbell, the highest possible ranking for ethical standards and legal ability. He has been named a Top Lawyer by DBusiness Magazine, a Rising Star by Super Lawyers, and a Leading Lawyer by Law Bulletin Media.

Adam Levitsky is an equity partner with GMH and a Member of its Board of Directors. Adam concentrates his practice in the areas of workers’ compensation defense, subrogation, general civil liability and criminal defense. He has successfully defended employers, their insurance companies, self-insureds and third-party administrators at all levels of the workers’ compensation process. He has extensive trial and appellate court experience in Michigan state and federal courts.

Ashley Brown

Recent Posts

Congratulations to Keela Johnson on Her 2026 Professional Accomplishment Award

Giarmarco, Mullins & Horton, P.C. proudly congratulates Keela Johnson, an equity shareholder and member of the…

1 week ago

Giarmarco, Mullins & Horton Announces Lindsay Hazen and David Occhiuto as New Shareholders

FOR IMMEDIATE RELEASE TROY, Mich. — October 19, 2026 — Giarmarco, Mullins & Horton, P.C.…

3 weeks ago

Anne Gabbert Appointed to State Bar of Michigan Lawyers and Judges Assistance Committee

Troy, Michigan — September 29, 2026 — Giarmarco, Mullins & Horton, P.C. is pleased to…

1 month ago

Elizabeth A. Favaro Named 2026 Leader in the Law by Michigan Lawyers Weekly

Troy, Michigan — September 28, 2026 — Giarmarco, Mullins & Horton, P.C. is pleased to…

1 month ago

Giarmarco, Mullins & Horton, P.C. is pleased to announce that Lindsay Hazen, a member of…

1 month ago

Giarmarco, Mullins & Horton Attorneys Recognized Among 2026 Michigan Super Lawyers and Rising Stars

GMH is proud to announce that 11 attorneys have been recognized on the 2026 Michigan…

2 months ago