I just realized something: when BL Firestorm killed Ghehenna in BL3, why was she not risen as a BL? Yeah, she was a pile of table salt by then, but that didn't stop BL Dr. Light from rising from a pile of melted wax!
It's either a big plot hole or something that hasn't happened just yet. Firestorm's been a big part of the main series so far, so this may still happen later on.
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