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The Complainant established that the Respondent violated the Wisconsin Fair Employment Act by discriminating against her on the basis of sex and age with respect to salary increases. Since the U.S. Supreme Court issued its decision in Amtrak v. Morgan, 536 U.S. 101, 122 S. Ct. 153 (2002), a number of federal courts that have considered claims of discriminatory compensation have limited recovery in such actions to discriminatory paychecks received within the limitations period. They treat each of the prevailing plaintiff’s paychecks that included discriminatory pay as a discrete discriminatory act. Following these cases, the Complainant in this case could only recover for the discriminatory pay raises that she received within the 300 days before she filed her complaint with the Equal Rights Division. Gaulke v. Sch. Dist. of Stratford (LIRC, 12/08/06)
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