State v. Allen

Defendant appeals from four misdemeanor convictions for issuing false financial statements. Imposition of sentence was suspended on all four convictions, and defendant was placed on probation. He was ordered to serve jail time as a condition of probation for each conviction.

Two of the convictions were based on misconduct that occurred after November 1, 1989, but before June 10, 1991. During that time, the statute in effect did not authorize jail time as a condition of probation. State v. Wold, supra n 2, 105 Or App at 160. In 1991, the legislature amended ORS 137.540(2) to allow jail time as…