Devlin appeared on the show's second season for a brief period as Laurie's (Busy Philipps) love interest Smith. Since leaving the programme, Devlin has landed a guest role in ABC drama Brothers & Sisters.
However, Biegel believes that there could still be a chance for Smith and Laurie to rekindle their relationship.
"Once someone exists in the world, they exist in the world," Biegel told E! Online. "If there's a next year for Cougar Town, he can definitely show up next year.
"Maybe Laurie will be in a different place, but I totally think he's someone who could pop up again."
Cougar Town continues on Wednesdays at 9.30/8.30c on ABC.