Roberts appeared at Sydney's Downing Centre Local Court on Tuesday, when a magistrate heard the ex-NSW State of Origin representative had not worked in six months and was receiving Centrelink benefits to make ends meet.
The 31-year-old, who played more than 160 NRL games for five clubs during his playing career, earlier pleaded guilty to breaching a condition of an AVO not to make contact with his de-facto partner, Anna Jovanovic.
One charge of stalking or intimidation against him was withdrawn by prosecutors on Tuesday and dismissed by the court.
James Roberts played for West Tigers and four other NRL clubs. (Joel Carrett/AAP PHOTOS)
Roberts' lawyer told the court the reason he was calling Ms Jovanovic was to make contact with his children and he fully accepted his wrongdoing
"He frankly admits the breach; he called her outside the hours," the lawyer said.
"He was having trouble getting through to the children at the agreed times.
"It was only ever about that."
The police prosecutor argued there are other ways to deal with the situation other than "pestering and harassing" Ms Jovanovic.
"It wasn't just a one-off phone call - it was 33 phone calls over a period of one-and-a-half months," the prosecutor said.
According to court documents, Roberts made a Facebook post in October suggesting Ms Jovanovic was not allowing him communication with his children.
Magistrate Scott Nash said he understood the positions of both parties and noted the need to deter others from similarly breaching AVOs, which were designed to protect potential victims of domestic violence.
He accepted Roberts' reasons for breaching the AVO as being to try to make contact with his children.
James Roberts was handed a 15-month conditional release order. (Bianca De Marchi/AAP PHOTOS)
"That might provide an explanation but not an excuse," Mr Nash said.
But rather than record a conviction on Roberts' record, the magistrate opted for a 15-month conditional release order.
The AVO was extended for an additional two years, with Mr Nash urging Roberts to prove the breach was out of character.
"I think in the circumstances where it is towards the lower end of seriousness … I'll treat this as an aberration on his part," he said.
The court was told Roberts' lack of contact with his children caused him "grave sadness", likely contributing to issues with depression.
"He was a first-grade NRL player but at the time of the breakdown of his relationship ... his career came to an end," Roberts' lawyer told the court.
"He has no income except for Centrelink."
He was arrested in October outside the Downing Centre Local Court after appearing for a brief court mention.
Roberts played for the Wests Tigers, South Sydney Rabbitohs, Penrith Panthers, Gold Coast Titans and Brisbane Broncos across 12 seasons in the NRL.
He appeared in all three games for NSW in the team's successful 2018 State of Origin campaign and played for the Indigenous All Stars and City Origin before retiring in 2022.
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