Rios was due in LA County Superior Court Thursday morning but could not attend because she was still in the hospital. The crash occurred Tuesday when she allegedly drove her SUV into a Los Angeles Metro bus at high speed.
The impact embedded her vehicle into the bus and killed two passengers. Rios and several other passengers were also seriously injured in the collision.
The bus crash set off a chain reaction that led to the deaths of three people in the NBC helicopter accident.
Rios is facing murder charges, and her bail was set at $4.03 million. She remained hospitalized as of Thursday, when she was expected in court.