But San Bernardino Superior Court Judge Michael Smith never got the chance to make a ruling because Fowler, who appeared in a green jail jumpsuit, withdrew his motion.
In November, Fowler wrote a letter to the court asking for additional counsel or new counsel and said his current lawyer was ineffective.
Smith scheduled an informal hearing for Friday, where he planned to discuss the matter with Fowler and his lawyer, Don Jordan, and decide whether Fowler and Jordan could continue working together as attorney and client.
Instead, Smith confirmed Fowler's sentencing date, which is scheduled for Jan.
In September, jurors recommended that Fowler receive the death penalty for the 2003 wildfire that consumed more than 90,000 acres in the San Bernardino Mountains and which, prosecutors contended, led to the deaths of five men.
That same jury convicted Fowler on Aug. 15 of five counts of first-degree murder and two counts of arson in connection with the blaze, which burned more than 1,000 structures.
Throughout the trial, Fowler said he did not start the fire.
After the court hearing on Friday, Jordan said he is still contemplating filing a motion for a new trial.
"There are three witnesses that, I believe, were with Fowler at the time of the fire," he said.
If the defense team can find those people, they plan to bring forward the new motion.
The motion will have to be filed before Fowler's January sentencing date.
Reach Lori via email or call her at 909-483-9378, or find her on Twitter @IEcourtsNow