State v. Pakula
In State v. Pakula, 113 Ariz. 122, 547 P.2d 476 (1976), the defendant had been charged in a single information with eleven counts of obtaining money by false pretenses. 113 Ariz. at 123, 547 P.2d at 477.
He pled guilty to all counts. Id.
The trial court sentenced him to prison on the first count and imposed consecutive, three-year terms of probation on each of the remaining ten counts. Id.
The supreme court first observed that "there is no express provision by statute or rule which permits the superior court, on multiple counts in the same information, to impose consecutive periods of probation." Id. at 124, 547 P.2d at 478.
It then concluded "that the consecutive terms of probation following imprisonment in the state prison was not an authorized sentence." Id. at 125, 547 P.2d at 479.