Terry Lynn Barton will wait a while longer to be resentenced.
Barton is the 42-year-old former U.S. Forest Service employee who admitted setting the largest wildfire in Colorado history.
Her public defender, Mark Walta, says her resentencing has been delayed indefinitely while the Colorado Supreme Court reviews a similar sentencing situation from Montezuma County.
Barton was sentenced on state charges to 12 years in prison in 2003 -- which is twice the typical term.
But the Colorado Court of Appeals ordered a new sentencing, saying the judge in the case may have been biased because smoke from the Hayman wildfire forced him to evacuate.
Fourth Judicial District Judge Thomas Kennedy ruled this year that a jury could consider whether enough aggravating circumstances existed to justify Barton's sentence.
Barton had been serving her state sentence simultaneously with a sentence she received after pleading guilty to federal charges including arson.
She remains at the Federal Medical Center Carswell in Fort Worth, Texas.