"She should know better than that," said Judge Wayne Salvant.
Tonya Couch failed a drug test back in March and was released in May after making bond.
Ethan Couch and his mother fled to Mexico in January but later returned to the U.S.
Ethan Couch's legal team presented a document to a court in western Jalisco state seeking to end the effort
No date has been set for the return of the Texas teenager and his mother from Mexico.