Cultic Studies Journal, Vol. 14, No. 2, 1997, page 38
through “objective” perspective and refined techniques, help resolve his or her
problems and (3) the notion that a person must conform to the therapist‟s
perceptions and comply with the therapist‟s plan if he or she is to improve. The
client is in a “one-down” position relative to the therapist, and, therefore, exhibits
a higher degree of compliance in that special relationship than might exist in any of
the person‟s other relationships. (Haley, 1973, p. 185)
The evidence, however, is otherwise. Claims that there are thousands of women suffering
from “false memory syndrome” (FMS) are clearly hysterical, and not scientific, reports.
Hysteria also fuels the rhetoric linking “recovered memory” therapists to the Salem Witch
Trials (Gardner, 1991) or, even more repulsive and insulting, to the extermination of Jews
by the Nazis.
The numerical figures of victims who have had false memories of childhood sexual abuse
implanted by therapists is generally drawn from the number of people who have contacted
the False Memory Syndrome Foundation (FMSF). But it is foolish to believe that every
person who contacts that group is necessarily a victim. Likewise, it is equally as fallacious to
believe all recanters as it is to believe all accusers. Quite some time ago Erickson (1938)
discussed repressed memory and the legal phenomenon of false recanting. It is also foolish
to believe that perpetrators openly will admit their crimes and will not seek refuge in an
organization like the FMSF and it is clear that some proportion of perpetrators will be
amnestic for the sexual abuse and therefore will sincerely believe in their own innocence.
In the only data-based scientific study to examine “false memory syndrome” on a
population of women who alleged that they had been victims of childhood sexual abuse,
Hovdestad and Kristiansen (1996) correctly note that “evidence for the claim that
pseudomemories are stimulated by suggestive therapy techniques could, by definition, be
collected only from women with recovered memories” (p. 319). Hovdestad and Kristiansen
found that (1) “although 60.8% of the participants with recovered memories reported that
their memories of the abuse...first surfaced at a time when they were in therapy, reports of
the use of potentially suggestive techniques were rare” (p. 319) (2) hypnosis was used in
only 7.8% of the cases (p. 320) 6 (3) “women with recovered memories and those with
continuous memories did not have different demographic profiles” (p. 327) (4) “there was
no evidence that recovered memories were associated with certain types of therapy in fact,
39.2% of the women recovered their memories independent of therapy” (p. 328) and,
most significantly, (5) “at most, 3.9% of women with recovered memories could be
diagnosed with FMS, and the absolute estimates gave an upper limit of 13.6%, a rate
equivalent to that among women with continuous memories” (p. 329). Hovdestad and
Kriastiansen conclude that “even if the finding that 3.9% of the women with a recovered
memory met the criteria for FMS was misinterpreted to argue that 3.9% have false
memories, the false-allegation rate would be identical to the rate of false allegations for any
crime, be it rape, robbery, or homicide” (p. 330). Thus, as the authors note, FMS may be
“real,” but it is exceedingly “rare” (p. 330). Karlin and Orne‟s image of therapy as a false
memory manufacturing warehouse thus flies in the face of the facts. By contrast, however,
these statistics are entirely consistent with the analysis presented in Brown et al (1997).
Given the reality of childhood sexual abuse, and the facts that (1) patients will report it
whether or not it happened, and (2) perpetrators will deny it whether or not it happened,
what should therapists do? Karlin and Orne recognize the Buridan‟s Ass dilemma when they
note the problem therapists face in working with memories of childhood sexual abuse:
Whenever psychotherapists occasion a patient‟s recovery of a forgotten memory of
ICA, a perpetrator takes the blame for the patient‟s misery. The patient and the
people who believe her may punish the remembered perpetrators without remorse.
If the recovered memories of ICA were correct, it would be difficult to fault this

Cultic Studies Journal, Vol. 14, No. 2, 1997, page 39
position. But all too often, the “recovered memories” are destructive fantasies,
shaped and elicited by a therapist who believes that ICA is at the root of the
disorder and memories of it await uncovering by hypnosis. Exploring this
hypothesis often devastates the accused, the accuser, and other family
members.... This harm is occasioned by the transfer of the patient recollections of
abuse from the therapeutic context to interactions with persons meaningfully
involved with the patient outside therapy. Given the fictive nature of the narrative
developed in psychotherapy (Spence, 1982), this is simplistic, naive, and
unfortunate. (p. 66)
Thus, Karlin and Orne express a bias in disbelieving reports of childhood sexual abuse
because “all too often” these reports are shaped by bad therapists. In fact, however, the
reverse is true, as demonstrated by the Hovdestad and Kristiansen (1996) study. All too
often, the reports are all too true. The Karlin and Orne bias does not obscure the important
point that they are here admitting that long buried reports of childhood sexual abuse can be
true. As long as it is possible that the memories may be true, therapists must work with
them in therapy as if they are true (Scheflin, 1997a).
An extension of this negative and critical focus appears in Karlin and Orne‟s belief that when
a patient visits a therapist, a “fictive nature of the narrative [is] developed in
psychotherapy” (p. 66). Because they see the whole therapy process as the social
reconstruction of fantasy and imagination, which is exactly how they also see hypnosis,
Karlin and Orne discount the historical truth of what comes out of therapy. Do they really
think (1) that grieving patients basically make up stories with therapist collaboration so that
the whole narrative is untrue? Or (2) that the “fictive nature” of the therapy narrative is any
different than the fictive nature of autobiographical memory in general, including the stories
we tell family, friends, and colleagues?
If we add to this belief in the fantasy story told by the patient Karlin and Orne‟s additional
belief that therapists are manufacturing false memories by the thousands, we have a pretty
good picture of the Karlin and Orne premises. First, patients are not to be believed. Second,
therapists are not to be believed. Third, hypnosis is not to be believed. Fourth, hypnotically
refreshed recollection is not to be believed. And fifth, recollection in therapy is especially not
to be believed. It is no wonder that Karlin and Orne favor a per se exclusion rule!
In my opinion, Karlin and Orne have become too mesmerized by Spence‟s (1982) distinction
between historical truth and narrative truth. Taken as an absolute, the distinction is
dangerously erroneous, as I have argued in Scheflin (1997a).
Karlin and Orne are silent concerning what therapists should do with memories of childhood
sexual abuse. We all agree that therapists should not implant or create such memories, but
what if such memories spontaneously arise? As Karlin and Orne note, the memories may be
“correct” or they may be “destructive fantasies.” There is no litmus test by which to tell the
truth of any memory (Spiegel &Scheflin, 1994). As Kihlstrom (1993b) notes in his paper
“Exhumed Memory”:
Do we have any way of telling which memories are valid, and which are the
product of imagination? The short answer is no. In the final analysis, then there do
not appear to be any internal criteria --that is, standards that can be applied to
the statements themselves --that can serve to distinguish between accurate
recollections and fabrications and confabulations. Nothing substitutes for external
criteria --that is, the verification of individual statements by objective evidence. In
the absence of such independent corroboration, we have no means of reliably
distinguishing between fact and fantasy.