In a twist, a special referee in the disciplinary case against Steven Donziger said the suspended attorney should be allowed to practice law again, despite a federal judge's opinion that Donziger had scammed Chevron in a corrupt Ecuadorian court.

John Horan of Fox Horan & Camerini, a referee tasked to determine an appropriate punishment for Donziger, said that disbarment would be "too extreme," in a Monday report to legal disciplinary authorities.

Horan recommended to the Appellate Division, First Department, to end Donziger's suspension. The court has yet to rule on whether to accept Horan's recommendation and could decide to impose a harsher sanction.