[eluser]danmontgomery[/eluser]
You can't re-populate file inputs. This isn't a codeigniter limitation, but an HTML limitation (if we're calling it a limitation, which I don't really think it is). Regardless, set_value() checks POST data, and uploaded files are in $_FILES, not $_POST.
If you want to repopulate a file upload field, you would need to store the file regardless of form validation and note that a file has been uploaded another way.