Jeff Vespa/Wireimage
May 20, 2010 01:10 PM

A Los Angeles judge has lost her patience with Lindsay Lohan‘s excuses.

Lohan, 23, pulled a no-show at her progress review hearing Thursday because her attorney Shawn Chapman Holley told the judge the actress’s passport was stolen at the Cannes Film Festival this week. “She filed a police report. She intended to fly back at the earliest possible time. I don’t know what else to tell you. She had reservations for a flight,” she added.

“There is no valid excuse [for Lohan not being here], Judge Marsha Revel countered. “If she wanted to be here, she could’ve been here. She could’ve come two days early from Cannes. She has a history of not keeping scheduled appointments. She has to take this seriously. I’ve warned her before.”

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The judge ordered an arrest warrant for Lohan and set bail at $100,000, although it remains unclear whether authorities will apprehend the starlet on sight after she arrives in L.A.

“In general, when we encounter a person who passes through customs with an active warrant, we arrest the person and hold them for local authorities,” U.S. Customs and Border Protection spokeswoman Christina Gamez tells PEOPLE.

‘Reason to be Concerned’

If Lohan is apprehended and posts bail, the judge ordered Lohan to abstain from alcohol, be fitted with an alcohol-monitoring bracelet, and be subject to random drug testing once a week. The judge suggested in court that Lohan’s tardiness could be due to drug use and there was “reason to be concerned.”

Despite Lohan receiving a favorable report from her court-mandated alcohol education program this month, Judge Revel said Lohan may be in violation of her probation because she previously ordered the actress to attend the class at least “once a week without fail.”

A probation violation hearing date is pending Lohan’s return to court. If found in violation, the prosecutor overseeing the case, Deputy District Attorney Danette Meyers, stated she would seek up to six months in jail for the starlet. Meyers also stated that she wants proof that Lohan had indeed purchased a flight ticket to make Thursday’s hearing, otherwise that would show Lohan was “snubbing the court.”

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Court spokesman Allan Parachini said Lohan would likely be subject to the alcohol-monitoring bracelet and drug testing even if she voluntarily surrenders to the court. “It was my impression [the judge] would impose those conditions the next time she sees Ms. Lohan.”

Beyond Her Control

Holley argued that Lohan is in “substantial compliance” with her probation and her absence Thursday was due to a situation beyond the actress’s control. Holley said Lohan would return to court as soon as possible.

The actress’s father, Michael Lohan, who has been vocal about getting his daughter into rehab, made an appearance in the courtroom, and nodded his head in agreement with the judge’s orders. “Michael’s concerned about his daughter’s well-being,” his attorney said after the hearing. “We’re pleased that the judge placed stricter orders on her.”

At the actress’s last in-person progress review, Judge Revel sternly warned Lohan not to create any more misunderstandings or “thumb her nose at the court” lest she face jail time.

This is the second time the judge issued a warrant against her.

As of now, Lohan will remain on probation until August next year.

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