Lindsay Lohan in court

Lindsay Lohan in court (L.A. Times / May 24, 2010)

Holley told reporters that Lohan tried to board a plane last Tuesday but was turned back at the airport because she didn't have a passport.

The actress filled out a police report in Cannes and obtained a temporary passport, Holley said.

Lohan has completed 10 out of her 13 required alcohol education classes, Holley said, adding that her client has an excellent progress report.

"Does she reschedule at times? Yes. Is she late sometimes? Yes. But she makes all of that time up," she said.

"This is a young woman who is complying with the conditions of her probation and could not be here because of something outside of her control," Holley added.

Lohan was spotted partying on a yacht in Cannes Wednesday night.

Issuing a bench warrant is standard practice when a person misses a court date, but they are usually put on hold for a few days to give the person another opportunity to come to court, according to Jane Robison of the Los Angeles County District Attorney's Office.

In August 2007, Lohan pleaded no contest plea to two counts each of driving under the influence and being under the influence of cocaine, along with a reckless driving charge.

At the Oct. 16 progress hearing, Revel scolded Lohan, saying she must notify the court and get permission before leaving the jurisdiction again.

"I don't want to get any notices again -- and I don't want you thumbing your nose at the court," Revel told Lohan, adding that "the most important thing" is that the actress "continue to recover."

"I don't want any more notices from the program that you may be in violation because you are absent for 21 days," Revel said.

"I am rooting for you to successfully complete probation," Revel said. "I want there to be no more misunderstanding. This has to be a top priority."

Revel also warned Lohan that because she is followed closely by the media, she won't be able to tell the court one thing and do another.

"Your life is followed -- it's not as if you can just hide out," Revel said. "Too many people know what you're doing."

About 5:15 a.m. on May 26, 2007, Lohan crashed a Mercedes-Benz SL65 into a hedge along Sunset Boulevard in Beverly Hills and was charged with drunken driving.

In July of that year she was arrested in Santa Monica in connection with a dispute with an assistant. She subsequently underwent rehab for alcohol and substance abuse.

Under the terms of her plea deal, she was placed on 36 months probation, required to serve a 24-hour jail sentence, complete an 18-month alcohol education program and perform 10 days of community service.

Lohan served 84 minutes in the Lynwood jail as part of her plea deal and was ordered to undergo alcohol and drug rehab as a condition of her probation.