It also doesn't work on Jetty 6.1.x, but I think that's a bug in Jetty.
On another note (to quote the article above):
With version 2.1 or later, the character sequence #{ represents a deferred expression, assuming the attribute has been declared to support deferred expressions in the TLD. If the attribute does not support deferred expressions, then the presence of the #{ character sequence results in a translation error.
This seems to imply that if Struts produced a JSP 2.1 TLD for its tags, it could turn off the support of #{} on a per-attribute basis.
Matt