Christopher Horn v. G&H Auto Group, Inc. d/b/a Mohawk Chevrolet

District Court, N.D. New York·Decided September 10, 2026·No. 1:24-cv-01457·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

CHRISTOPHER HORN,

Plaintiff,

v. 1:24-cv-01457 (AMN/PJE)

G&H AUTO GROUP, INC. d/b/a MOHAWK CHEVROLET,

Defendant.

APPEARANCES: OF COUNSEL:

HARDING MAZZOTTI, LLP KELLY A. MAGNUSON, ESQ. 1 Wall Street Albany, New York 12205 Attorneys for Plaintiff

THE TOWNE LAW FIRM, P.C. JOHN W. LIGUORI, ESQ. 500 New Karner Road MEGAN L. BASSLER, ESQ. Albany, NY 12212 Attorneys for Defendant Hon. Anne M. Nardacci, United States District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION On December 2, 2024, Plaintiff Christopher Horn (“Plaintiff”) commenced this action against G&H Auto Group, Inc., otherwise known as Mohawk Chevrolet (“Mohawk Chevrolet” or “Defendant”), alleging employment retaliation under Title VII and New York State law. Dkt. No. 1. Presently before the Court are cross-motions for summary judgment (the “Motions”), pursuant to Rule 56 of the Federal Rules of Civil Procedure, by Mohawk Chevrolet, see Dkt. No. 30 (“Defendant’s Motion”), and by Plaintiff, see Dkt. No. 34 (“Plaintiff’s Motion”). Both Motions have led to responses in opposition and replies in further support. See Dkt. Nos. 38, 41 (response and reply to Defendant’s Motion); Dkt. Nos. 37, 42 (response and reply to Plaintiff’s Motion). For the reasons set forth below, the Court denies both Motions. II. BACKGROUND Mohawk Chevrolet is a car dealership located in Ballston Spa, New York. Dkt. 37-2 at ¶

6. From August 4, 2022, to January 10, 2023, Plaintiff was employed by Mohawk Chevrolet as a salesperson. Id. at ¶ 16, 18. Plaintiff’s termination at the end of that period, eight days after he reported that a co-worker had been sexually harassed by a manager, is the subject of this lawsuit. In addition to Plaintiff, this case principally involves three individuals in management at Mohawk Chevrolet: co-owner Andy Guelcher (“Guelcher”), General Manager Travis Horne (“Horne”), and General Sales Manager Katie Duncan (“Duncan”). See id. at ¶¶ 8-15. It is undisputed that when Plaintiff was hired by Mohawk Chevrolet in August of 2022, he directly negotiated an abnormally favorable pay plan with its co-owner, Guelcher. Id. at ¶¶ 20-21; Dkt. No. 38-1 at ¶¶ 10-11. The other salespersons at Mohawk Chevrolet were paid based on their

meeting progressively increasing “tiers” of sales goals. Dkt. No. 30-12 at 44:21-45:13. If a vehicle sale was profitable enough, the salesperson would receive a certain percentage of the dealership’s profits, with a higher percentage for more profitable deals—and if not, the salesperson received only a flat payment.1 See id. at 44:21-45:13; Dkt. No. 34-13 at 29; Dkt. No. 38-1 at ¶ 9. Unlike

1 More precisely, they earned commission compensation on the sale’s “front end gross profits,” which refer to the sale price of the vehicle less the price the dealership paid for the vehicle. See Dkt. No. 30-12 at 45:21-46:14. Back end gross profits, in contrast, refer to those made beyond the vehicle itself, such as on the customer’s financing deal with the dealership. See id. at 105:22- 106:10. Plaintiff not only received a guaranteed thirty percent commission on front end gross profits, he also received five percent on back end gross profits—an exceptionally profitable deal for him, since the back end gross profits could prove quite “stout.” Id. at 105:11-15, see Dkt. No. 38-1 at ¶ 8. those employees, Plaintiff made a guaranteed percentage at or above the top “tier” of the other salespersons, regardless of any individual car deal’s profitability or his overall sales. See Dkt. No. 37-2 at ¶ 20; Dkt. No. 38-1 at ¶¶ 5-10; Dkt. No. 30-12 at 43:10-46:2. This made Plaintiff’s compensation higher than all of Mohawk Chevrolet’s other sales associates. See Dkt. No. 38-1 at ¶ 17.

But while this arrangement was comparatively favorable to Plaintiff, another aspect of his compensation led to friction between him and Mohawk Chevrolet. The disagreement arose over Plaintiff’s commission compensation on holdbacks. Here, a “holdback” refers to a payment from the vehicle’s manufacturer directly to the dealership on a car’s sale. Dkt. No. 30-9 at 36:24-37:7. Every vehicle is sold to a dealership with a manufacturer-recommended final price. Dkt. No. 30- 12 at 46:7-14. When the dealership sells that vehicle to an end customer, the manufacturer reimburses some percentage of the recommended final price back to the dealership to help cover general and administrative expenses. See id. at 105:16-106:3. But while the dealership profits from both the vehicle sale and the holdback payment, a salesperson is typically paid commission

only on the sale, not on the holdback. See Dkt. No. 38 at ¶ 4; Dkt. No. 30-9 at 37:4-5. Plaintiff wanted to be paid on both his vehicle sales and the associated holdback payments. Dkt. No. 30-9 at 37:2-3. Accordingly, he requested as much when he joined Mohawk Chevrolet. Dkt. No. 38-1 at ¶ 2. The parties now dispute whether Mohawk Chevrolet accepted or declined that request. Id. at ¶ 7. What they do not dispute, however, is that Plaintiff was paid on holdbacks until December 2022. Id. at ¶ 14. Mohawk Chevrolet contends that this was overpayment due to an “accounting error,” which was corrected when it was uncovered. Id. at ¶ 14. Afterwards, Mohawk Chevrolet told Plaintiff that his compensation would no longer include payment on holdbacks moving forward, though they permitted him to “retain the overpayment and . . . did not request that Plaintiff pay it back.” Id. at ¶ 15-17. Plaintiff disagrees with this characterization, contending that Mohawk Chevrolet reneged on his agreement with Guelcher that he would be paid on holdbacks. Dkt. No. 37-2 at ¶ 26. When he was informed that he would no longer be paid on holdbacks, he proceeded to raise the issue with General Sales Manager Duncan—who he believed had ordered the change in his pay, see Dkt. No. 30-9 at 50:19-51:16—and they scheduled a meeting

for January 2, 2023, to discuss the issue.2 Dkt. No. 37-2 at ¶¶ 27-30. Up to this point in his employment, Mohawk Chevrolet contends that Plaintiff had several “performance deficiencies,” which Plaintiff disputes. Dkt. No. 38-1 at ¶¶ 19-25. Though Plaintiff was never the subject of an “official write-up,” Duncan testified that managers “had issues with him not abiding with what the sales consultants were supposed to do on a day-to-day.” Dkt. No. 30-12 at 21:4, 21:17-23. Specifically, Duncan contends that Plaintiff was not conducting sufficient client and social media outreach, see id. at 22:2-24:5, and not properly logging phone calls with customers, see id. at 28:3-11. Duncan testified that Plaintiff received multiple “corrective conversations” that did not result in him fixing those issues. Id. at 30:13-23. But no

contemporaneous documentation of those corrective conversations is in the record, Dkt. No. 37-2 at ¶ 89, and Plaintiff testified that he did not recall being counseled or disciplined for his insufficient phone contacts. Dkt. No. 30-9 at 45:7-16, 60:15-17. Further, Duncan’s recollection is only partially supported by the testimony of other Mohawk Chevrolet employees. Compare Dkt. No. 30-11 at 20:3-7 (“[Plaintiff] had . . . numerous meetings with [General Manager] Mr.

Free access — add to your briefcase to read the full text and ask questions with AI

Christopher Horn v. G&H Auto Group, Inc. d/b/a Mohawk Chevrolet, (N.D.N.Y. 2026).

Christopher Horn v. G&H Auto Group, Inc. d/b/a Mohawk Chevrolet (Christopher Horn v. G&H Auto Group, Inc. d/b/a Mohawk Chevrolet) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Meritor Savings Bank, FSB v. Vinson
477 U.S. 57 (Supreme Court, 1986)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
St. Mary's Honor Center v. Hicks
509 U.S. 502 (Supreme Court, 1993)
Kaytor v. Electric Boat Corp.
609 F.3d 537 (Second Circuit, 2010)
Rodriguez v. City of New York
72 F.3d 1051 (Second Circuit, 1995)
R.B. Ventures, Ltd. v. Shane
112 F.3d 54 (Second Circuit, 1997)
Gibbs-Alfano v. Burton
281 F.3d 12 (Second Circuit, 2002)
Joseph v. Treglia v. Town of Manlius
313 F.3d 713 (Second Circuit, 2002)