After losing the United States Championship to Bobby Lashley, JBL was wrote off WWE television for a while, as well as losing a main event "loser leaves town" title match to Rey Mysterio. It's expected that the JBL-Teddy Long angle will play out over several weeks until JBL is brought back in to television. JBL has been nursing an injury on his lower back so has needed time outside of the ring to recover from it.
Despite there not being any definite plans for JBL to re-capture the WWE Title from Rey Mysterio at Judgement Day, JBL's injury certainly influenced the decision to continue with Rey as champion. Pro Wrestling Torch goes on to report that Rey Mysterio requires knee surgery to clean out loose particles in his knee. However, if his knee does hold out over the next few months it's expected that a feud between himself and Chavo Guerrero will happen. However this all depends on the status of Rey's knee, and whether it gets to the point where he needs time off from the ring.