"Ariel is smart, beautiful and talented. She is a legitimate actress. She does not need to do this. She is beautiful with her clothes on," she said.
Winter became emancipated in 2015 after accusing her mum of abusing her physically and emotionally.
Her mum isn't the only one attacking her dress sense.
After she posted racy bikini snaps on Instagram over Memorial Day weekend, many deemed them inappropriate.
Winter defended herself.
"Could not be more grateful to all of the men and women who risk their lives to protect ours and our freedom, We are all forever indebted to your service. Thank you," she wrote.
Then, in May, she was questioned about the risque cut-out dress she wore to a Modern Family daytime event, while her co-stars dressed casually.
"Why TF does anyone care that I didn't dress casual like everyone else for the panel? Why do I have to be like everyone else? Why can't people just let other people feel good about themselves and do what they want?" she said.
Winter underwent a breast reduction in 2015 to reduce her boobs from a size F to a D.
She has spoken out before about her body image issues growing up and claims it was her mum who tried to "sexualise" her at a young age.
Doesn't appear like the mother and daughter will be mending fences anytime soon.