Manhattan Supreme Court Justice Ellen Gesmer warned Frankel's attorney Allan Mayefsky on Thursday, "No more pajamas!," E! News reported.
Mayefsky reportedly insisted the stunt was just a joke, but Gesmer didn't find it funny.
"It's not a joke. Her child is not a joke," said Gesmer, calling the incident "ridiculous."
The judge has reportedly been presiding over Frankel, 43, and her estranged husband Jason Hoppy's divorce proceedings.
Frankel ignited a controversy by posting an Instagram photo of her wearing her daughter Bryn's clothes, which fit her, in July. She joked about whether they were ready to start sharing clothes.
"When ur 4 year old peanut says 'mommy please put my dress on' & giggles uncontrollably, u do what ur told," the 43-year-old former Bethenny Ever After star tweeted at the time in response to photo criticism.
"BREAKING NEWS! World Scandal: Former reality star, failed talk show host & cocktail maven jokes by wearing her kids' pjs! #itcantbetrue."
On a pre-taped episode of The Meredith Vieira Show airing Friday, Frankel addressed the hype, saying, "The truth of the matter is I don't really care what people think if I don't think I've done anything wrong," according to E! News.
"It was a dress of my daughter's, and she's like, 'Put this on,' and one of my friends was like, 'Your Instagram game is weak.' So I just took a picture and thought it was cute. I had no idea that I would get that backlash."
She reportedly added, "I had no idea, and I really didn't think it was that big of a deal. I didn't think people were going to start being anorexic because I put my daughter's clothes on. I just thought it was a ridiculous joke."