E! News said it is unclear why she was handcuffed and placed behind bars after a scheduled hearing, during which she was assigned a new lawyer, Tuesday morning in New York Supreme Court.
Sabourin, who claims she and Baldwin had a romantic relationship, was arrested in April on suspicion of aggravated harassment and stalking.
She was released on her own recognizance and ordered to stay away from the "30 Rock" star.
E! News said she since has been commenting on Baldwin and his new wife Hilaria via Twitter.