Dina Lohan was due to appear in Nassau County Family Court to arrange visitation rights to her two youngest children - daughter Aliana, 13, and son Dakota, 10 - with her estranged husband Michael.
Dina's lawyer Warren Quaid told the hearing his client was preparing to fly to California to visit Lindsay in rehab.
Judge Stacy Bennett angrily said, "All future dates she is required to be here."
Mean Girls actress Lindsay was charged with driving under the influence after crashing her car in Beverly Hills, California on 26 May (07). She checked into a rehab facility shortly afterwards.
Source: WENN