Memory & Abuse:

The Recovered Memory Controversy

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What Psychologists Better Know About Recovered Memories:
Research, Lawsuits, and the Pivotal Experiment

Kenneth S. Pope

SUMMARY: The following article reviews 6 major scientific, ethical, and legal issues raised in the book The Myth of Repressed Memory by Elizabeth Loftus and Katherine Ketcham. It examines the assertion that a study by Lindsay and Poole revealed that there are "over 1 million cases of 'recovered memories' each year"; looks at the use of the ad hominem fallacy; notes legal actions undertaken by 2 members of the FMSF Advisory Board that not only raised the issue of a conspiracy directed against them but also accused the American Psychological Association of engaging in racketeering activity; examines Wakefield and Underwager's defamation suit against a prominent psychologist and the resulting judge's opinion about litigating science; and reviews some high-profile cases involving Paul McHugh and others that illustrate the complex issues in this area.

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"I study memory, and I am a skeptic," writes Loftus in The Myth of Repressed Memory (p. 7), dedicating the book "to the principles of science, which demand that any claim to 'truth' be accompanied by proof" (p. v). A distinguished faculty member of the University of Washington's Department of Psychology and School of Law, she co-authored Witness for the Defense: The Accused, the Eyewitness, and the Expert Who Puts Memory on Trial with Katherine Ketcham in 1991. Like their previous work, The Myth of Repressed Memory is told from Loftus's first-person perspective. Their new book advances the theme of Witness for the Defense: Here the expert puts recovered memory of abuse on trial. In my opinion, The Myth of Repressed Memory will be her most influential work. It goes beyond numerous anecdotes, vividly told. In its description of experiments as well as other tales of recovered memories, the Loftus and Ketcham book touches on many of the ethical, professional, and legal issues of this field. Six major questions can be noted: choosing sides, telling stories, requiring proof, remaining silent, bringing suit, and guiding practice and policy [footnote 1].

Choosing Sides

The first issue involves the choosing of sides. Loftus characterizes it this way:

On one side are the "True Believers," who insist that the mind is capable of repressing memories and who accept without reservation or question the authenticity of recovered memories. On the other side are the "Skeptics," who argue that the notion of repression is purely hypothetical and essentially untestable, based as it is on unsubstantiated speculation and anecdotes that are impossible to confirm or deny. (p. 31)

What are the data supporting and what are the likely consequences of labeling those with whom one disagrees "True Believers"? Loftus makes clear her source by quoting from Hoffer's well-known text The True Believer (1965/1989). If the skeptic demands proof, how does the True Believer decide what to believe in? Hoffer observed that True Believers shut themselves off from facts, ignoring a doctrine's validity while valuing its ability to insulate them from reality (Hoffer, 1965/1989, p. 80). Hoffer described the True Believer's passionate hatred and fanaticism, noting:

the acrid secretion of the frustrated mind, though composed chiefly of fear and ill will, acts yet as a marvelous slime to cement the embittered and disaffected into one compact whole. (p. 124)

Similarly, a number of False Memory Syndrome Foundation (FMSF) board members, including Loftus, compare those who are on the other side to the hunters and murderers of "witches." The book returns repeatedly to the central metaphor of the "hysteria" characterizing "an earlier time when God-fearing citizens, gripped by fear, superstition, and religious fervor, cried witch, and a forest of stakes was pounded into the very heart of the community" (p. 228). Quotations from Arthur Miller's The Crucible precede the first page of the book and chapters 2-4. Historically, hysteria typically has been used to label women, in this case the allegedly large proportion of female therapists who seem to implant or otherwise elicit false memories and the allegedly large proportion of women who assert false memories. FMSF claims that at least 90% of those whom they described as "accusing adult children" who are afflicted with the syndrome and about 75% of their therapists were female (Wakefield & Underwager, 1992, p. 486; see also Freyd, Roth, Wakefield, & Underwager, 1993; it is unclear what FMSF means by the oxymoronic term "adult children" and how FMSF scientifically distinguishes adult children from other adults). Wakefield and Underwager (1994) emphasize that psychiatrist Richard Gardner "sees the women who make false allegations based on recovered memories as very angry, hostile, and sometimes paranoid. He believes that all will have demonstrated some type of psychopathology in earlier parts of their lives" (p. 332).

Aside from attributing group characteristics (e.g., True Believers, hysterical murderers of those falsely accuse as "witches") to those who disagree with their beliefs about recovered memories, some who have served on the FMSF advisory board have also made attributions about individuals with whom they disagree. Wakefield and Underwager (1994), for example, discuss professor of cognitive psychology Jennifer Freyd "hiding" behind a "dishonest facade," which they describe as "the contemptible last refuge of fools and the beginning of conscious knavery" (p. 289).

Loftus is right to remind us of the demand that proof accompany assertions; many are making assertions about various people who work in this area. Some assertions are quite broad; they characterize all who are on "the other side." Some are extremely personal; for example, in addition to remarks about Freyd cited above are published allegations from other FMSF sources about her sexual relationship with her husband, how she nurses her infant, her mental health, etc. (Doe, 1991); one document containing many such propositions was distributed to her university colleagues while she was being considered for promotion to full professor. Those who make the assertions bear a heavy responsibility to ensure that the published evidence accompanying the assertions meets the highest standards of scientific proof, to state clearly how making allegations about sexual relationships or nursing are valid and relevant forms of professional discourse (as opposed to being a form of ad feminam rather than logical argument), and what limits of civility, respect, or basic human decency are to be recognized in characterizing those with whom one disagrees on an issue.

Telling Stories

Concerns about incompetent or malicious therapists remain abstractions until embodied in a specific person. This book uses many anecdotes to illustrate its view of the horrors perpetrated by therapists whose patients experience recovered memories. Loftus tells the story of her friend "Barbara" (a pseudonym), describing her as a crusading, sometimes strident colleague, whose toxic friendship taught Loftus much about how the therapeutic process can be abusive (p. 223). Loftus alleges that a specific individual had sexually molested her when she was 6 and that she had kept it a secret rather than telling her parents.

When Loftus tells the story to her friend Barbara, Barbara does not put this decades-old product of malleable memory on trial or even ask Loftus for external evidence that the event really happened. To the contrary, Barbara apparently begins the True Believer's bizarre, frightening, and almost psychotic activities. Barbara is clearly, in Loftus's word, "abusive." In Loftus's memory, Barbara apparently lacks boundaries and the ability to differentiate other people's feelings from her own; she sends Loftus a horrifying rendering of genital mutilation. Finally, Loftus understands how Barbara had mistreated and victimized her: "I knew what Barbara had done-- she had stolen my memory, stuck pins in it, and made it bleed" (p. 226). Loftus's dramatization of her victimization by Barbara and of her own pierced and bleeding memory raises complex questions about psychologists' telling stories about their "friends" to illustrate abusive events or other phenomena.

The path this book uses to dramatic immediacy may exact a high price. The book states, "Certain scenes and dialogue have been dramatically recreated in order to convey important ideas or to simplify the story" (p. xi). Perhaps there is another meaning to this statement, but in context it seems to mean that when the authors did not know what had happened, they made up words and actions based on what they thought the people might have said, and shaped this imaginative exercise to communicate certain ideas or reduce complexity so that a certain story would emerge clearly. How readers can figure out when the book is dramatically recreating scenes and dialogue involving people and events intended to be real and when it uses other methods of description (e.g., based solely on authenticated documents or solely on the memory of the authors) is unclear. Although the dramatization of supposedly actual events by those who were not present has become widespread in books (e.g., McGinniss, 1993), what are the likely results? Loftus herself asserts, "Cognitive psychologists know that when people engage in exercises in imagination, they begin to have problems differentiating what is real and what is imagined" (p. 158).

While the portrayal of Barbara has the persuasive power of narrative, readers have a responsibility, in my opinion, to consider carefully such questions as these: Aside from the distortions of memory, were Barbara's words and behaviors recreated to dramatize a specific point and was a much more complex and ambiguous story simplified so that it would more neatly support Loftus's view of the True Believer? If there were a videotape of what was supposedly an extremely private expression of self-disclosure and friendship, would it differ significantly from Loftus's account? What are the strengths and weaknesses of using an exchange between friends as a basis for assessing "a great deal about the inherent and potentially abusive power of the therapeutic process" (p. 223)? What responsibilities, if any, does a psychologist have when intending to publicize a friend's attempts to help as a negative example? An additional issue in dramatically recreating scenes and dialogue of actual people is that pseudonyms may be relatively transparent, especially (as in this case) when surrounding information seems to point to a readily identifiable person.

The book's dramatic recreations and more factual descriptions make it fairly easy to tell the skeptics from the True Believers. If therapists travel in "swarms" (p. 251), have faces "red with anger" (p. 34), or start "swatting" Loftus over the head with a newspaper (p. 211), they are likely True Believers. But if the professionals are noticeable by their "dark, soulful eyes" (p. 252), the description characterizes a skeptic (in this case fellow FMSF advisory board member Richard Ofshe). Readers might ask themselves if such characterizations are relevant and valid, and if so, how they increase our understanding of this area. For example, were Loftus as staunch an advocate for True Believers as she currently is for skeptics, would the skeptics in this book be flushed, swarming, and swatting? Would skeptical challenges to her positions be dismissed as unscientific and based on "the prejudices and fears that lie behind the resistance to my life's work" (p. 4)?


The nature of and responses to child abuse have attracted vigorous examination. For example, FMSF executive director Pamela Freyd once wrote as Jane Doe that to oppose child abuse constitutes conformity with the widely ridiculed "pc" movement: "To be against child sexual abuse is a 'politically correct' position" (p. 163; see also Freyd, 1994).

According to Loftus, the scientific proof is supposedly adequate to support the truth of the claim: recalling abuse is inevitably followed by a variety of specific, harmful consequences that seem to constitute a checklist. Loftus and Rosenwald (1993), for example, discuss "the psychological upheaval, the ruined reputations and careers, and the breakup of families that inevitably follow the supposed recall of abuse in childhood" (p. 70). Loftus's conclusion that upheaval, ruin, and family breakup are universal regardless of the specific family, the nature of abuse supposedly recalled, whether the individual discloses the supposed recollection to anyone else, and other factors, may powerfully influence the damages phase of legal actions against those who recall memories of abuse and/or their therapists. But where is the proof of this assertion?

Obviously, anyone is free to make an absolute statement about all recall of abuse and may rely upon clinical experience, a collection of anecdotes, an appeal to authority, or countless other justifications. But a scientific approach, according to Loftus, demands that the assertion of truth be accompanied by proof. Moreover, readers must have the proof presented in sufficient statistical detail to address questions about whether the sweeping conclusions were warranted in terms of the base rates of psychological upheaval, ruined reputations and careers, and family breakup for the general population on which this research was based.

A careful examination of proof with regard to diverse conspiracy allegations would be extremely useful. Repeatedly, claims of powerful groups cooperating in illegal, destructive behaviors seem to arise in this area. For example, those who recover memories may describe conspiracies of Satanists, who perform secret ceremonies involving child abuse and murder. Those who testify for the defense in child abuse cases may describe what seems like a conspiracy of those who seek to protect children. In their recent book, Wakefield and Underwager (1994), for example, claimed: "This child protection system is allied with a law enforcement system that commits illegal acts such as murder and fabrication of evidence" (p. 36).

Ofshe and Singer, two of Loftus's FMSF advisory board colleagues, have raised the issue of a conspiracy directed against them. They filed a federal suit against the American Psychological Association (APA), American Sociological Association (ASA), and various individuals, alleging racketeering activity connected with an effort to destroy Ofshe and Singer's ability to function as professionals and to testify as expert witnesses in certain trials (Singer & Ofshe v. APA et al., 1992, p. 3). One question this suit raises is: Can those who sue an organization be regarded as unbiased experts in other legal actions whose principals are members of the organization?

These plaintiffs also filed a suit in state court alleging that APA, ASA, and others conspired in a number of acts, including attempts to obstruct justice, deceiving federal judges, mail fraud, and defamation (Singer & Ofshe v. APA et al., 1994a, p. 7). The complaint noted that both Singer and Ofshe derived a substantial portion of income from consultations and work as expert witnesses, and discussed how Ofshe was greatly emotionally distressed in light of how his potentially jeopardized credibility could affect his clients. (For additional information, see Singer & Ofshe v. APA et al., 1993; Singer & Ofshe v. APA et al., 1994b).

Assessing conspiracy claims and other assertions requires not only requesting proof but also analyzing the methods by which that proof is obtained. Judge Yule, for example, held that Ofshe's methods seemed in some regard to be those of which he is critical when discussing therapists working with recovered memories. "Just as [Ofshe] accuses [therapists] of resolving at the outset [to find] repressed memories of abuse and then constructing them, he has resolved at the outset to find a macabre scheme of memories progressing toward satanic cult ritual and then creates them" (Crook v. Murphy, 1994a, p. 27).

Remaining Silent

Loftus remains silent on some important issues. She states flatly, "I have stopped arguing statistics" (p. 34). Her reluctance, however, makes it difficult to understand the assumptions underlying descriptive and inferential statistics that she cites. For example, she supports an assertion about therapists that "fully a quarter of them are engaging in beliefs and practices that are risky if not dangerous" (Loftus, 1994) by citing a study in which survey forms were sent to U.S. and British psychologists (Poole, Lindsay, Memon, & Bull, 1995). Findings were presented in terms of country, age, gender, theoretical orientations, experiences, beliefs, and behaviors using 145 forms from U.S. psychologists and 57 forms from British psychologists. Psychologists need to scrutinize the assumptions underlying research in which percentages are reported to the second decimal when bases are less than 100 (see Table 2, p. 429), a number of t tests and chi-squares are conducted without a plan for controlling Type I error, and an inadequate sample size is used for characterizing the large population of therapists in two countries across numerous variables. [For a more fundamental and comprehensive critique see "Are 25% of Clinicians Using Potentially Risky Therapeutic Practices? A Review of the Logic and Methodology of the Poole, Lindsay et al. Study" by Karen A. Olio in Journal of Psychiatry & Law, Summer, 1996, pages 277-298.]

Following Loftus's lead in terming those on the other side "True Believers," Pendergrast (1995) has examined the 25% figure and other findings reported by Poole and her colleagues. Pendergrast believes that social workers or master's-level counselors contain a larger percentage of True Believers, but uses the more conservative 25% figure.

Poole and Lindsay's survey indicated that 25 percent of doctoral-level therapists constitute True Believers. . . . Taking that 25 percent figure as accurate, however--and ignoring the substantial number of "recovered memories" that arise outside that core group--we arrive at 62,500 True Believer therapists. Poole and Lindsay found that each therapist saw approximately 50 female clients per year, of whom 34 percent recovered memories.

Using simple math (62,500 True Believers x 50 clients x 34 percent who recover memories), we arrive at over 1 million cases of "recovered memories" each year. . . .

And that is only an estimate of women who have recovered memories at the hands of hard-core, True-Believer, licensed therapists. It doesn't account for men who have recovered memories. . . . (p. 491; italics in original)

Similarly, Loftus might have discussed portions of her own work spanning 3 decades that seem relevant to the book's attack on the myth of repression. Early in 1994, for example, her own data led her to observe: "There is a reason to believe that the 19% figure we obtained in the current study may actually be an overestimate of the extent to which repression occurs" (Loftus, Polonsky, & Fullilove, 1994, p. 81) and "One could argue that this means that robust repression was not especially prevalent in our sample" (p. 80). In the prior decade she discussed "motivated forgetting" and presented a documented study of a college professor who became unable to remember a series of traumas but after a long period of time was able to recover memories of the traumas. "

Eventually, R. J. was able to remember all of her traumatic experiences. . . . Even though the return of her memories made her wiser, she was also much sadder. More than most of us ever will, R. J. understood the true meaning in Christina Rosetti's words in Remember: "Better by far you should forget and smile than that you should remember and be sad" (Loftus, 1980/l988, p. 73).

Discussing an example of response to a single trauma (i.e., unlike R. J.'s response to a series of traumas), Loftus asserted: "After such an enormously stressful experience, many individuals wish to forget . . . and often their wish is granted" (p. 73). And in the 1970s, Loftus wrote:

Memories that may cause us great unhappiness if they were brought to mind often appear to be "forgotten." However, are they really lost from memory or are they simply temporarily repressed as originally suggested by Freud (1922)? Repression is the phenomenon that prevents someone from remembering an event that can cause him pain and suffering. One way that we know that these memories are repressed and not completely lost is that the methods of free association and hypnosis and other special techniques used by psychotherapists can be used to bring repressed material to mind and can help a person remember things that he has failed to remember earlier. (Loftus & Loftus, 1976, p. 82)

Discussing the experimental evidence of repression, she reviews an analog experiment by Zeller (1950) and explains: "This experiment indicates that when the reason for the repression is removed, when material to be remembered is no longer associated with negative effects, a person no longer experiences retrieval failure" (p. 83).

Suing Professionals and Litigating Science

As an expert witness, Loftus has testified extensively for the defense. She testified that all of her courtroom testimony in criminal cases was on behalf of defendants and that in civil cases focusing on repression and child abuse she had testified only for defendants alleged to have engaged in abuse (Smith v. Smith, 1993, pp. 4, 6-7).

Her recounting of courtroom experiences encourages us to consider how the methods of science and the methods of litigation differ, their influence on each other, and, in the words of one court, the need for "more papers, more discussion, better data, and more satisfactory models" (Underwager and Wakefield v. Salter, 1994, p. 11). Those who work in the area seem compelled to keep an eye on the courts and their power. FMSF, for example, informed accused parents that they could seek guardianship proceedings by making legal claims that the child who has recovered memories is incompetent ("Legal Aspects of False Memory Syndrome," 1992, p. 3). No action, however, was deemed as desirable as filing a malpractice action against the therapist.

The best course of action is by the child who realized the error of the accusations made, and recants and brings an action for malpractice, against the therapist. It would seem that there is a very real possibility that the parent could join in this action.... Therapists, medical institutions and insurance companies will be seriously threatened by such actions ("Legal Aspects of False Memory Syndrome," 1992, p.3).

Novel suits in two California cities blamed a popular book for leading people to believe false memories of sex abuse and satanic ceremonies ("Author Target of False Memories Lawsuit," 1994, p. B3; Butler, 1994).

Two members (actually, one is a former member) of the FMSF advisory board filed an interesting suit. After psychologist Anna Salter wrote a case study exploring the relationship of claims made by psychologists Ralph Underwager (credited with coining the term "false memory syndrome") and Hollida Wakefield to the primary research and original sources, Drs. Underwager and Wakefield sued Salter, claiming defamation. The appellate court noted: "Underwager served on the board of the False Memory Syndrome Foundation until resigning after being quoted as telling a Dutch journal that sex with children is a 'responsible choice for the individual"' (Underwager and Wakefield v. Salter, 1994, p. 6).

The appellate court summarized some salient aspects of Underwager and Wakefield's career:

Psychologists Ralph Underwager and Hollida Wakefield have written two books.... They conclude that most accusations of child sexual abuse stem from memories implanted by faulty clinical techniques rather than from sexual contact between children and adults. The books have not been well received in the medical and scientific press. A review of the first in the Journal of the American Medical Association concludes that the authors took a onesided approach: " . . . When a given reference fails to support their viewpoint they simply misstate the conclusion. When they cannot use a quotation out of context from an article, they make unsupported statements, some of which are palpably untrue and others simply unprovable." . . .

Underwager's approach has failed to carry the medical profession, but it has endeared him to defense lawyers. He has testified for the defendant in more than 200 child abuse prosecutions and consulted in many others. (pp. 1-2)

The court described Underwager's testimony "that children are incapable of correctly remembering or accurately describing sexual contacts" and cited other cases in which courts (e.g., Washington state's Supreme Court) had concluded that Underwager's work was not embraced by the scientific community. In addressing the belief "that Underwager is a hired gun who makes a living by deceiving judges about the state of medical knowledge and thus assisting child molesters to evade punishment,' the court held that

Scientific controversies must be settled by the methods of science rather than by the methods of litigation.... More papers, more discussion, better data, and more satisfactory models--not larger awards of damages--mark the path toward superior understanding of the world around us. (pp. 10-11)

Practice and Policy

The Myth of Repression documents how court involvement has raised complex practice and policy questions about memory disturbance, acceptable interventions, and personal responsibility. The highly publicized case of American University President Richard Berendzen illustrates many of these questions. The same day President Berendzen resigned, he entered Johns Hopkins (Spevacek & Gonzales, 1990). The police had caught him making what were described as "terroristic," obscene phone calls (Vatz & Weinberg, 1993, B4).

When staff at Johns Hopkins injected sodium amytal, Berendzen began talking about childhood abuse (Brown & Sanchez, 1990, A1).

He was sweaty and woozy and groggy.... And the psychiatrists who surrounded his bed kept bombarding him with questions.... He slept for a few hours, and then ... it was time for group therapy. Still groggy, he staggered down the hallway and slumped into a seat among the child molesters and the rapists and the exhibitionists who were his fellow patients. "And this doctor suddenly riveted me to the wall--wham!--with these questions and everybody's staring at me and he's going back to all these things when I was a kid. And the first thing that jolted me was: How the hell does he know that?" (Carlson, 1990, W12)

During this time, according to a reporter, Berendzen "told them about events that he'd totally forgotten" (Carlson, 1990, p. W12). He himself noted that when he engaged in sex with his parents, "Once it was over, it was erased" (Berendzen & Palmer, 1993, p. xi). In treating Berendzen, the Johns Hopkins staff also used age regression (Berendzen & Palmer, 1993, p.123), guided imagery (pp. 154-155), focus on a famous case of alleged child abuse (p. 122), imaginary letters to his mother (pp. 131--132), and bibliotherapy that included symptom checklists (p .157) . In light of staff assurances that Berendzen would always be treated just like any other patient (p. 152), it may surprise readers to learn of patients' constant access to staff: "McHugh said that even though Berlin was my attending physician, he wanted me to have his home number and told me to call if I ever needed him" (p. 153).

The Johns Hopkins evaluation allowed Dr. Paul McHugh, chief psychiatrist and FMSF board member, to reach a number of specific conclusions. Appearing with Berendzen on television the same day of the court hearing, McHugh compared the phone calls to "a kind of foreign body imprinted in him earlier in his life" ("Berendzen pleads guilty to obscene calls," 1990, p. 2). McHugh concluded that the phone calls were symptoms:

We concluded that Dr. Berendzen is a patient, and this behavior that he has had, of these telephone calls, are symptoms of that patienthood, that he is suffering from-- in a kind of post-traumatic disorder, provoked by serious--the most serious kind of sexual abuse to him when he was a child. (p. 2)

McHugh's report to the court asserted that the calls were not obscene (Berendzen & Palmer, 1993, p. 187). A woman who had taped some of the calls noted that one involved the graphic description of "a four-year-old Filipino sex slave locked up . . . in a dog cage.... And the only thing that she was fed was human waste" ("Berendzen pleads guilty to obscene calls," 1990, p. 1). McHugh's report to the court emphasized that these nonobscene calls had nothing to do with Dr. Berendzen's prurient interests but were an attempt to bring resolution to his own abuse-caused patienthood (Cohen, 1990, A21). The report submitted to the court emphasized that the patient was now sound psychologically and physically (Spevacek & Gonzales, 1990, A1). Finally, "Dr. McHugh said after the weeks of treatment that Mr. Berendzen will 'never indulge in that behavior again'" (Vatz & Weinberg, 1993, B4). The history of child abuse was highlighted in the court hearing less than a month after he had entered the hospital, and he received a suspended sentence.

As reported by McHugh, Berendzen, and the media, these events highlight some intensely discussed questions about working with adults who claim to have been abused as children after a long period during which, in Dr. Berendzen's words, they "somehow don't remember it any more" ("Berendzen pleads guilty," 1990, p. 4). When child abuse is reported 40 years later, can clinicians or forensic specialists decide with certainty that it did or did not occur? Are sodium amytal, age regression, guided imagery, probing memories of famous cases of alleged child abuse, assigning reading materials containing symptom checklists, and similar techniques useful in assessment and intervention? Can interrogations conducted in a darkened hospital room or an intensive therapy group distort findings? Can the possibility that a forensic expert may appear on national television with the patient affect the process and outcome of a forensic assessment? What, if any, are the implications of forensic expert and patient appearing on television shows together? Can a clinician determine whether a patient experienced prurient interest during phone calls, and what are the assumptions underlying making this distinction? Have sufficient controlled research studies been published in peer-reviewed journals to provide an empirical basis for assuring courts, after less than a month, that someone who has made non-obscene but illegal phone calls in the past will "never indulge in that behavior again"? Can childhood abuse suddenly cause the symptoms of posttraumatic stress disorder 40 years later, and if so, can a course of assessment and treatment of less than one month bring about such a complete recovery that the patient is now sound?

Two profound policy questions are: (a) should a person who only after arrest claims a history of child abuse be exempt from jail and fines for seemingly abusive and illegal behavior? and (b) are the forensic uses of mental health syndromes scientifically based and consistently applied? For example, McHugh's colleague at Johns Hopkins, John Money, criticized the FBI's handling of the complaint against Sol Wachtler, chief justice of New York State's highest court, arguing that no one should hold Wachtler responsible for his actions because he suffered from advanced symptoms of an erotomanic delusional disorder, which is a devastating illness (Derschowitz, 1994, pp. 323-324).

Leo (1994) comments that the illness afflicting a prominent judge arrested for such symptoms as extortion and threats to kidnap a 14-year-old girl (the daughter of a woman with whom Wachtler, unknown to his wife, had been sexually active) is one that apparently can be diagnosed from 300 miles away, that telephoning the patient or even knowing much about him is unnecessary, and that all the clinician needs to know is that the patient is blameless. Leo has described how Money compared Berendzen's condition, as he did Wachtler's, to epilepsy (i.e., an illness that rendered the individual not responsible for his own acts).

When a 17-year-old patient claimed that a dentist had assaulted her, more than 20 people told the police that he had also fondled them (Gordon & Ordine, 1992, Bl). At the trial, Graboyes, the dentist, admitted that he had begun fondling patients at least 19 years earlier (Gordon, 1991). When Graboyes pled guilty to indecent assault and corruption of a minor, the district attorney's office asked for jail time. Harold Lief, a member of the FMSF advisory board, testified that jail would not be useful because Graboyes was mentally ill and suffered from a sexual disorder. The judge sentenced him to probation and ordered that he obtain treatment for his illness. Afterward, Graboyes observed that his mental illness had rendered him totally disabled and sued to ensure that he would receive $5,000 a month disability payments for life.

Leo (1994) raises a vital issue of policy and practice:

People at the top of society are far more likely to get away with psychologized and neurologized excuses than people in rough neighborhoods. John Money offered his epilepsy analogies, not after drive-by shootings, but in defense of a college president and a chief judge.... The psychologized vocabulary of moral evasion afflicts the whole society, but it is most corrosive when it lets the powerful off the hook.... [I]t is crucial to our sense of justice that high-placed perpetrators be held accountable, and not disappear into the mists of psychology" (pp. 24-25, 28; for discussion of this issue in the case of the dentist, see Gordon, 1991).


I believe The Myth of Repressed Memory is one of the few books that are must reading among the array that vigorously attack those whom Loftus terms True Believers. In only 290 pages, it covers a diversity of anecdotes, ideas, data, and assertions. It addresses crucial issues confronting the profession and the public.

In an area in which so much is at stake, it can be almost irresistible to stake out an extreme position and defend it by attacking those who disagree as True Believers, as comparable to murdering and superstitious witch hunters, as dishonest knaves and fools, and similar characterizations. But the fact that so much is at stake is a compelling reason to avoid such attacks, to rethink the FMSF claim that filing a lawsuit is "the best course of action," to consider the unintended consequences of imaginatively dramatizing supposedly nonfiction accounts, to ensure that no relevant data--one's own or others'--are excluded from evaluations of evidence, and to assess the degree to which assertions of truth are accompanied by proof.

What I view as flaws in this book (e.g., dismissing those who disagree as True Believers) distract and detract from the value of Loftus's contributions and the serious questions she raises. In my opinion, they do her and the field an injustice. Not only the two sides that Loftus describes but all sides have important ideas, data, questions, creativity, experience, wisdom, and concerns to contribute. The current state of research and the complexity of issues would seem to make blanket claims of "truth" or "myth" at best premature and at worst destructive. Even if I or anyone else were convinced of an extreme and absolute position--that all recovered memories are true or that all represent a false memory syndrome--a rethinking of the position, respectful discussion with those who disagree, and another look at the evidence can only be healthy. Both scientifically and clinically, avoiding reflexive acceptance or rejection of an idea or allegation is crucial. Each client, claim, and hypothesis deserves careful, unbiased evaluation in light of the full range of available evidence and context. Even once we have conducted such an evaluation and feel absolutely certain of our conclusions, we can always be wrong and must never overlook that possibility. It is hard to overstate the need for "more papers, more discussion, better data, and more satisfactory models."

Footnote 1

The original article appearing in Clinical Psychology: Science and Practice contained an introductory section on the "Lost in the Mall" experiment. However, since that experiment was discussed in more detail in 2 subsequent American Psychologist articles, that section is omitted here. Readers interested in the material in those 2 articles are referred to "Memory, Abuse, and Science: Questioning Claims about the False Memory Syndrome Epidemic" and "Science As Careful Questioning: Are Claims of a False Memory Syndrome Epidemic Based on Empirical Evidence?" See also and
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Author target of false memories lawsuit. (1994, May 4). Sacramento Bee, p. B3.

Berendzen pleads guilty to obscene calls. (1990, May 23). ABC News Nightline Show No. 2348.

Berendzen, R., & Palmer, L. (1993). Come here: A man overcomes the tragic aftermath of childhood sexual abuse. New York: Villard Books.

Boss, K. (1994, September 25). Into the past imperfect; Elizabeth Loftus challenges our total recall. Seattle Times, p. 8.

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Received November 16, 1994; revised November 28, 1994; accepted November 29, 1994.


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