Polanski’s attorneys had filed a motion urging Judge Peter Espinoza to sentence the director without him having to appear in the United States.
However Espinoza denied the motion at a hearing Friday, saying the only way the case could be resolved is if Polanski returned to California.
“He needs to appear,” Espinoza said. “Motion is denied.”
Polanski’s lawyers told reporters immediately after the hearing they would appeal the judge’s decision.
Polanski, 76, is under house arrest in Switzerland, where he has been held since his detention in September on an arrest warrant.