Cultic Studies Journal, Vol. 13, No. 1, 1996, page 30
What can be worse? What can be worse than incestuous pedophilic abuse? Incestuous
abuse involving multiple perpetrators, not only the father but also other adults, such as the
mother and the father‟s friends, may be “remembered” as sexually abusing the patient. The
patient may come to see ordinary memories of childhood as a lie, with monsters hiding
behind all the masks of caring faces. What could be worse? Being sexually abused during
satanic rituals and forced to drink the blood of dead animals. (As we will see below, this is
one of the events reported by Joan Borawick.) By this time the patient has learned that she
had to develop a series of alters during childhood to protect herself from being
overwhelmed by the horrors inflicted on her.
Unbelievably, it continues. What could be worse? The patient learns that her family is part
of a multigenerational satanic cult her grandparents and great-grandparents were
members of the cult, and each generation was subsequently abused. It is now the patient‟s
turn. Additionally, the patient may learn that the cult programs some alters to be self-
mutilating and/or suicidal when that alter takes charge, the results can be injurious or
fatal. What scenario could be worse? The patient may remember being made into a breeder,
forced to bear babies who became slaves to the cult or, alternatively, were aborted, after
which the patient was forced to eat her own babies. By this time, members of the patient‟s
family may be remembered as high authorities in the cult, and one of the patient‟s own
alters may also be the high priestess. This alter must eat bits and pieces of thousands of
people each year (see Ofshe &Watters, 1994).
In vulnerable patients this process of escalating horrific fantasy induction reaches the point
of an enduring, confidently-held delusion. The delusion usually lasts at least so long as the
therapist, an attorney, or someone else significant to the patient is there to support it.
Remember, most forms of therapy are beneficent but all too often therapy that centers on
recovering memories of childhood abuse is not. Instead it is destructive of both patients and
those who otherwise would have been closest to them.
Moreover, although this depiction of recovered memory therapy includes extremes, it is by
no means a caricature. Some therapists who treat adult victims of recently recalled ICA do
not create an environment of escalating suggestions, but it happens often enough to be
frightening (cf. Loftus &Ketcham, 1994 Ofshe &Watters, 1994 Perry, 1995 Yapko,
1994). For example, a recent case received notoriety when a well-known psychotherapist
and authority on MPD was sued by a patient who no longer believed she was a satanic high
priestess. She claimed years of belief in satanic cults during psychiatric hospitalization were
due to suggestions in hypnosis that escalated unduly (Ofshe &Watters, 1994). This is not
an isolated case. Both of the present authors know psychologists and psychiatrists whose
practice includes a number of patients who have “learned” or are convinced that their
multiple personality disorder occurred as one result of satanic ritual abuse. Rather than
treating such fantasies with benign neglect, their diagnosis and ensuing suggestive
treatment serves to consolidate the fantasies into believed-in memories.
Borawick v. Shay
One approach to better understanding the problems we are discussing is to examine how
our courts are dealing with these issues. In a recent decision, the United States Court of
Appeals for the Second District sitting on a three-judge panel unanimously affirmed the U.S.
District Court ruling (Borawick v. Shay, 1995) to exclude the testimony of Joan Borawick, a
plaintiff seeking damages for incestuous childhood abuse allegedly inflicted by her aunt and
uncle, Christine and Morrie Shay. The plaintiff, who was herself a California attorney,
claimed that her aunt inserted a cap pistol and a broomstick in the plaintiff‟s vagina on two
separate occasions during family visits when she was 4 and 7 years old. In addition, the
aunt allegedly involved Ms. Borawick in some type of ritual dancing while both the aunt and
child were naked. On another occasion, during these visits, the plaintiff claimed that her
What can be worse? What can be worse than incestuous pedophilic abuse? Incestuous
abuse involving multiple perpetrators, not only the father but also other adults, such as the
mother and the father‟s friends, may be “remembered” as sexually abusing the patient. The
patient may come to see ordinary memories of childhood as a lie, with monsters hiding
behind all the masks of caring faces. What could be worse? Being sexually abused during
satanic rituals and forced to drink the blood of dead animals. (As we will see below, this is
one of the events reported by Joan Borawick.) By this time the patient has learned that she
had to develop a series of alters during childhood to protect herself from being
overwhelmed by the horrors inflicted on her.
Unbelievably, it continues. What could be worse? The patient learns that her family is part
of a multigenerational satanic cult her grandparents and great-grandparents were
members of the cult, and each generation was subsequently abused. It is now the patient‟s
turn. Additionally, the patient may learn that the cult programs some alters to be self-
mutilating and/or suicidal when that alter takes charge, the results can be injurious or
fatal. What scenario could be worse? The patient may remember being made into a breeder,
forced to bear babies who became slaves to the cult or, alternatively, were aborted, after
which the patient was forced to eat her own babies. By this time, members of the patient‟s
family may be remembered as high authorities in the cult, and one of the patient‟s own
alters may also be the high priestess. This alter must eat bits and pieces of thousands of
people each year (see Ofshe &Watters, 1994).
In vulnerable patients this process of escalating horrific fantasy induction reaches the point
of an enduring, confidently-held delusion. The delusion usually lasts at least so long as the
therapist, an attorney, or someone else significant to the patient is there to support it.
Remember, most forms of therapy are beneficent but all too often therapy that centers on
recovering memories of childhood abuse is not. Instead it is destructive of both patients and
those who otherwise would have been closest to them.
Moreover, although this depiction of recovered memory therapy includes extremes, it is by
no means a caricature. Some therapists who treat adult victims of recently recalled ICA do
not create an environment of escalating suggestions, but it happens often enough to be
frightening (cf. Loftus &Ketcham, 1994 Ofshe &Watters, 1994 Perry, 1995 Yapko,
1994). For example, a recent case received notoriety when a well-known psychotherapist
and authority on MPD was sued by a patient who no longer believed she was a satanic high
priestess. She claimed years of belief in satanic cults during psychiatric hospitalization were
due to suggestions in hypnosis that escalated unduly (Ofshe &Watters, 1994). This is not
an isolated case. Both of the present authors know psychologists and psychiatrists whose
practice includes a number of patients who have “learned” or are convinced that their
multiple personality disorder occurred as one result of satanic ritual abuse. Rather than
treating such fantasies with benign neglect, their diagnosis and ensuing suggestive
treatment serves to consolidate the fantasies into believed-in memories.
Borawick v. Shay
One approach to better understanding the problems we are discussing is to examine how
our courts are dealing with these issues. In a recent decision, the United States Court of
Appeals for the Second District sitting on a three-judge panel unanimously affirmed the U.S.
District Court ruling (Borawick v. Shay, 1995) to exclude the testimony of Joan Borawick, a
plaintiff seeking damages for incestuous childhood abuse allegedly inflicted by her aunt and
uncle, Christine and Morrie Shay. The plaintiff, who was herself a California attorney,
claimed that her aunt inserted a cap pistol and a broomstick in the plaintiff‟s vagina on two
separate occasions during family visits when she was 4 and 7 years old. In addition, the
aunt allegedly involved Ms. Borawick in some type of ritual dancing while both the aunt and
child were naked. On another occasion, during these visits, the plaintiff claimed that her
