Col. James Pohl rejected an argument by the defense that he asked inappropriate questions of a witness, the reputed abuse ringleader Pvt. Charles Graner.
Graner's testimony for the defense at England's sentencing hearing contradicted her version of what happened, forcing a mistrial that ended her plea deal and put the case back on track for trial.
"But for your line of questioning, we would not be at the point of mistrial," argued Capt. Jonathan Crisp, lead defense lawyer.
Pohl disagreed, saying the defense called Graner to the stand knowing his testimony would run counter to England's plea.
"Don't lay it on me, Captain Crisp," the judge snapped. "It was not the questions that caused the problems. It was the answers."
England, 22, a reservist from West Virginia who appeared in some of the most notorious photographs from the 2003 scandal, is the only soldier charged with abusing prisoners at Abu Ghraib whose case has not yet been resolved. She faces two counts of conspiracy, four counts of maltreating detainees and one count of committing an indecent act. The charges carry a maximum of 11 years in prison.
The hearing was scheduled to resume Friday with a motion by Crisp to remove some of the photos from evidence.
England's new trial is set to begin early next month.