I'm running on 3.2.3, and I have three virtual hosts (each of which have their own docBase. The JSPs are in that directory (rather than in a common WAR)
Well, it took a while of screwing around, but I finally got it. I had to set the appbase in the virtual host definition (which I set to the same directory as the docbase for each host). I could then create a WEB-INF directory inside of the virtual host directory and the compile picked up the files in the classes/lib subdirectories.