Martin McDermott escaped from the low-security Loughan House open prison in County Cavan on March 15.
He was eight months into a seven-year sentence for killing a garda when he rammed his car in County Donegal.
The 26-year-old, whose address was given as c/o Maghaberry Prison, received a seven-year jail sentence in Letterkenny in July 2011 following his conviction for the manslaughter of Garda Gary McLoughlin.
Garda McLoughlin died after the squad car he was driving was struck at speed by a car driven by McDermott at Burt in December 2009.
A prosecution barrister told Judge Piers Grant that after his arrest in the Galliagh area of Derry following a cross-border search on the morning of March 22, McDermott pleaded guilty to assaulting three PSNI officers, resisting arrest and disorderly behaviour.
The barrister said McDermott, who has 91 previous convictions, ran into on-coming traffic at Fern Road, climbed over a wall and ran off when he saw members of a police foot patrol.
After a brief search, McDermott was caught and arrested. He was verbally abusive to the police officers, assaulted three of them and also damaged a set of police handcuffs.
The barrister said following his arrest, McDermott was taken to Strand Road PSNI Station where he admitted the offences and apologised to police for his actions.
He told them he had panicked and run off when he saw the police officer because of a bad childhood experience and because he suffers from post-traumatic stress.
Appealing against the four-month sentence imposed by Derry Magistrates’ Court in March, barrister Sean Doherty, said the injuries sustained by the three police officers were minor and non-permanent. He also said the offences were not pre-mediated.
Mr Doherty said McDermott had served the equivalent of a three-month sentence for the Derry offences.
He also said that, as McDermott’s non-contested extradition hearing was due to take place in the High Court in Belfast on Friday, if McDermott was still a sentenced prisoner on that day, the hearing would not be able to go ahead.
Refusing the appeal and affirming the four-month jail sentence, Judge Grant said that, although McDermott had a small record in Northern Ireland, his 91 previous convictions in the Republic of Ireland included manslaughter, other offences of violence, as well as threatening individuals.
He said the decision of the district judge who jailed McDermott for four months was “quite right”.