For a very low level villain, the Human Flame had a series of fortunate instances in his battle against two Justice Leaguers: Red Arrow and Hawkgirl. Early on he was able to remove Hawkgirl’s flying advantage, and incapacitated Red Arrow with his flames. Sure, he inevitably lost in the end, but it took them a while to do so. Fortunately for the Human Flame, his luck continued and Libra was able to rescue him.
From – Justice League of America Vol. 2 #21