Shannon Proctor, 31, has been jailed for 12 months for his most recent offending, which involved stealing a vehicle in Wodonga while a girl was inside.

Magistrate David Faram said the July 11 incident, which occurred outside the Deli Bean Cafe, caused the victim "extreme fear".

Proctor had left Wodonga hospital following a car crash and mental health episode when his restraints were removed.

He made his way to the cafe, saw the Toyota Prado running with the girl inside, and told her to get out.

The vehicle was moving when she exited.

He was arrested in Footscray two days later.

Prosecutor Paul Kounnas told the Wodonga Magistrates Court the fact the 13-year-old girl was in the car was "concerning" and escalated the offending.

"A child is possibly the most vulnerable category of victim in these sorts of circumstances," he said.

Mr Faram noted there was no suggestion of violence.

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"But no doubt it was conduct that caused her extreme fear," he said.

The teenager had earlier told the court about the devastating impact the incident had had on her life.

Proctor had been released from prison only eight days before the offending.

He still has matters pending in Queensland once his Victorian sentence expires.

Mr Faram said there were many support services available if Proctor wanted to change.

"You have a very significant record of prior criminal offending and your life in large part has been a rollercoaster of sentencing and release back into the community," he said.

"You're still a relatively young man Mr Proctor and at some stage this has to stop.

"You've got another 30 to 40, or even 50 years to go.

"The nature of your offending and your apparent inability to deal with, I acknowledge, very significant factors in your life has led you to spend quite a significant period of your life in jail.

"There have been and remain big issues in your life.

"But things can get better Mr Proctor.

"It is my personal wish and hope that on the completion of this sentence ... that you're able to finally overcome some of these significant hurdles."

With time already served, Proctor will be released in less than six months.