Jacobson v. Bentzler
In Jacobson v. Bentzler, 127 Wis. 566, 107 N.W. 7 (1906), the plaintiff argued that a check was not paid on a Sunday, contrary to the Sunday law that prohibited business being conducted on the first day of the week, because the payment "was not made until the check had been paid at the bank," which was after Sunday. Jacobson, 127 Wis. at 568.
The court disagreed, responding that "it seems clear that acceptance of a check on a bank is in the nature of a conditional payment, which becomes complete when accepted and when the amount due on it is actually paid, and that such payment relates back to the time of its delivery." Id.
Because the payee received the check on Sunday, it did not matter when the check's funds were actually available; the payment date was Sunday, the day the payee received the check. See 127 Wis. at 568-69.