Tired of what she described as "violation after violation," Superior Court official, Stephanie Sautner, got tough with the actress after she was kicked off her latest community service assignment.
Lindsay looked pale and anxious during the dramatic hearing which saw her lawyers battling to defend her.
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"We're dealing with someone on probation. Most people on probation don't always do things perfectly," her lawyer, Shawn Holley, pleaded.
But the court was unimpressed with the judge saying: "If jail meant something in the state of California now, maybe I'd put her in jail,"
Despite the threat, she set a November 2 hearing to decide whether the Mean Girls star should serve another stint behind bars.
Bail was set at $100,000 (£63,000), but Lindsay's spokesman, Steve Honig, said it was immediately posted and the actress was later released from Airport Courthouse.
"Lindsay is hoping this matter will be resolved on November 2 and the court will reinstate probation and allow her to continue fulfilling her community service," Mr Honig said.
The development is just the latest in a long line of legal problems for the 25-year-old, who was given probation for drink driving in 2007 and a misdemeanor theft case this year.
She has also been behind bars four times previously, only to be released early due to overcrowding.