In 1988, In re Steven Winston, the court disagreeing with a disciplinary panel recommendation for disbarment, held that Winston's cocaine addiction put him out of contact with reality to an extent sufficient to raise serious doubts as to the willfulness of his actions and whether his actions were to a significant extent caused by a cocaine-induced mental illness. While his mental illness did not excuse his misconduct, the court held that it may be considered in mitigation of the sanction imposed and decided to suspend the attorney for 3 years, if he can prove his continued recovery. The court also recognized that Winston had remained drug free since seeking treatment following his 1986 suspension and had involved himself in directing special activities at a drug treatment center, speaking before civic groups, and helping on other nonlegal activities. Photograph.