The 2003 "Old Fire" burned more than 90,000 acres, destroyed more than 1,000 structures and resulted in the deaths of five people who died from heart attacks and other health problems during the fire and in the days and weeks that followed.
Already convicted of arson and murder, Fowler was back in court Friday to learn the jury's decision as to whether he should serve life in prison or be put to death.
Victims had to wait nearly 10 years for justice, but it took the jury about three weeks to decide whether Fowler should be put to death.
Jurors declined to talk with media Friday, but they did speak to the deputy district attorney.
"They said they wanted to go thoroughly through the evidence, and they were not under any compulsion to rush to judgment, they wanted to make sure that they were doing the right thing, and they wanted to be able to live with the decision for the rest of their lives," said San Bernardino County Deputy District Attorney Robert Bulloch.
But the jury recommendation may not matter at all if California voters decide to overturn the death penalty in November by adopting Proposition 34. Because of the implications of Prop. 34, the judge will wait until after the election to officially sentence Fowler.
The defense plans to file a motion for retrial.