Jesse James' ex-wife Janine Lindemulder has been arrested just two days after she lost custody of their daughter.

The former couple, which split in 2004, has been embroiled in a nasty legal battle over seven-year-old Sunny for years and James was initially awarded custody in 2009 when Lindemulder was jailed on tax evasion charges.

She was placed behind bars again in Austin, Texas earlier this year for allegedly harassing the TV mechanic in a series of threatening emails and voicemails, and earlier this week a judge in California gave James sole custody of the child.

On Wednesday, Lindemulder was arrested for allegedly harassing the star again, with TMZ.com claiming she had called the reality TV star more than 25 times a day.