Lindsay Lohan Races Back to LA

Lindsay Lohan Races Back to LA (ABC News)

Lindsay Lohan arrived in court in Los Angeles this morning after reportedly racing from New York's JFK Airport Tuesday.

During the actress' brief appearance for a pre-trial hearing on a probation violation charge, Judge Stephanie Sautner joked, "Glad to see you're feeling better."

CNN had earlier quoted a source saying that Lohan had initially claimed she was too ill to fly.

Her new lawyer, Mark Heller, had filed a doctor's note last week, saying the "Mean Girls" actress was suffering from an upper respiratory infection, according to CNN.

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TMZ posted a picture Tuesday of Lohan smoking a cigarette while shopping in New York City, which might have prompted her hasty return to Los Angeles.

The purpose of the hearing was to confirm that Lohan had replaced her previous lawyer, Shawn Chapman Holley, with Heller.

Heller, who is licensed in New York, tried a little New York charm on Sautner, who used to be a NYPD detective, but the judge didn't bite.

After a 10-minute hearing, the judge set a trial date of March 18. There's another pre-trial hearing March 1, but Lohan, 26, is not required to attend.

The upcoming trial is related to the misdemeanor charges the actress faces in connection with her car crash on the Pacific Coast Highway in June. She has pleaded not guilty to lying to police, driving recklessly and obstructing an officer from doing his duties.

But because Lohan was still on probation for a 2011 necklace theft case, her probation was revoked in December as a result of the charges stemming from the accident.

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The actress, who has a home in Los Angeles, could face 245 days in jail if it's determined she violated her probation.

Lohan's court appearance will be her first in nearly a year before Sautner, who released her from supervised probation in March but warned her to stop partying and grow up.

"You need to live your life in a more mature way, stop the nightclubbing and focus on your work," Sautner told Lohan at the time.

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But Lohan's troubles have piled up since then. Another case involving Lohan's alleged physical altercation with a psychic at a nightclub in November is still pending in New York.