Jocelyn Kirsch is back in federal court Tuesday on a parole violation from her high-profile 2008 case.
The 28-year-old Kirsch admits she stole a pocketbook and other items in Walnut Creek, California, where she now lives.
She is serving house arrest on the local theft charges.
Defense lawyer Ron Greenblatt says Kirsch briefly stumbled when she left prison in 2012 without mental-health treatment.
The one-time Drexel University student pleaded guilty to a sophisticated swindle with her then-boyfriend, University of Pennsylvania graduate Edward Anderton.
They stole the identities of friends and neighbors to pay for trips to Paris and Hawaii, $2,000 hair extensions and other luxuries.