He failed in an appeal on Monday and has again been found guilty of disturbing religious worship after storming a community church service on Mother's Day in 2019.
Erikson was jailed for 70 days in 2021 but appealed both the conviction and sentence.
Victorian County Court Chief Judge Peter Kidd on Monday found prosecutors had proven the charge and Erikson was guilty.
Prosecutor Bill Stougiannos told the judge a prison sentence was the only option .
"For some reason, people like this accused take it upon themselves to assert undue Christianity and what they want their world to be," he said.
"That's all good and well but it's got to be done within the rules."
About 20 parishioners were present during the service at the Metropolitan Community Church when Erikson got to his feet and asked: "Does your church marry Sodomites?"
Parishioners were shocked by the incident and Reverend Susan Townsend stood up and asked him repeatedly to leave.
He hurled further abuse, including at times calling the parishioners "degenerates" and "fa***ts".
A scuffle broke out and Erikson accused a male parishioner of pushing him in the chest. He eventually left the church and waited outside for police.
Erikson's conduct showed he didn't care about the rules, Mr Stougiannos said, adding that it was troubling that the ordeal was live streamed to followers.
Members of the church told the court in a pre-sentence hearing after the appeal decision on Monday that there was a sense of betrayal because they welcomed Erikson and his companions to worship with them.
Another said his actions made their safe place feel unsafe.
Erikson's lawyer Stephanie Wallace asked Judge Kidd to consider a three-month community corrections order.
But the judge said if there was to be a community order it would be much more significant than three months because Erikson's conduct needed to be publicly denounced and deterred.
"People need to know if they overstep the mark and in a calculated way ... then there are consequences," he said.
Ms Wallace said if he was considering prison then it should be less than the 70 days handed down by the magistrate previously.
She said he had spent the three years since the incident trying to better himself.
"He describes himself as a 'retired activist' now," she said.
"He wants to restart and move away from some of the influences in Victoria."
Erikson has spent a month in prison for offending that occurred after the May 2019 incident.
Ms Wallace said much of that was spent in isolation because of his perceived beliefs, and he fears the same will happen again if he's jailed.
Judge Kidd will sentence Erikson on Thursday.
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