In regard to the offense theft with two prior theft convictions, is a theft probation, not deferred, considered a conviction for purposes of jurisdictional enhancement for this crime? I have heard some argue that the defendant has to have an actual conviction with jail time served, not a probation for it to be useable and others have argued a probation is a conviction and therefore a probation can be used as a jurisdictional enhancement. I cannot find a case on point. Can anyone point me to a case or statute that answers this question?

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