Cultic Studies Journal, Vol. 14, No. 2, 1997, page 40
It seems quite clear to me that therapists cannot fairly be held to a standard that punishes
them if they believe memories that ultimately prove to be false or unprovable. Karlin and
Orne solve this problem by an irrebuttable presumption that the memories are always
wrong and so they should never be believed. Thus, although they know that such memories
may be true in some cases, they refuse to permit any inquiry into the truth in all cases. In
my view, by comparison, I believe therapists are entitled to believe what clients tell them
for the purpose of doing therapy, and for the purpose of meeting the requirements of
mandated reporting statutes (Levine, Doueck, &Associates, 1995). Historical validity is the
work of lawyers, not therapists.
In a very interesting paragraph on page 66, Karlin and Orne write about two „rare
exceptions” to the rule that “talk therapy” has produced “generally beneficent results”:
blaming mothers of schizophrenic children (“schizophrenogenic” mothers), and blaming
parents of autistic children. In both cases, according to Karlin and Orne, psychotherapy
blamed persons outside “the therapeutic alliance” for what are largely biochemical, and not
psychological, problems. Karlin and Orne claim that the profession was wrong in those
instances of blaming the innocent and that the profession must “avoid repeating such
harmful errors.” The crucial issue then becomes whether dealing with memories of
childhood sexual abuse is the same type of error as blaming mothers of schizophrenics or
parents of autistic children. It should immediately be clear that vast and important
differences are involved.
Childhood sexual abuse is real, it occurs to millions of children, and there are valid reasons
to assess blame. If schizophrenia and autism are biochemical in nature, the mothers or
parents can never be blamed for the condition. But if mothers or fathers are molesting their
children, blame is more than appropriate. Therapists, by hindsight, may have been wrong to
conclude that psychological processes shaped schizophrenia and autism, but they are not
wrong in noting that psychological processes underlie childhood sexual abuse.
Ironically, when therapists were completely wrong about the etiology of schizophrenia and
autism, no “false blame syndrome” movement developed urging that countless lawsuits and
disciplinary proceedings be filed against therapists. Now that most therapists are right that
childhood sexual abuse exists and causes lingering psychological problems, a “false memory
syndrome” movement preaches a full-scale legal assault on therapists, and it engages in
many reprehensible practices such as those chronicled by K. Pope (1996).
Retrieving Only Accurate Memories
1. Does hypnosis always contaminate memory?
Karlin and Orne assume that hypnosis always contaminates memory, and therefore,
safeguards never work. The “inevitability” thesis is well stated by false memory advocate
John Kihlstrom (1993a):
Remembering is an act of reconstruction in which expectation and inference play
major roles, whereas hypnosis is ultimately an act of the imagination in which
normal reality testing is set aside. The hallucinating subject may believe he sees
something, but there is nothing really out there the age-regressed subject may
believe she is five years old again, but she has not shrunk in the chair. Similarly,
subjects given suggestions for hypermnesia may believe that they have recovered
new memories, but this information may not be accurate. In the absence of
objective corroborating evidence, there are no tests that can be applied to
determine whether a memory is accurate. The situation is made worse by the fact
that suggestion is central to hypnosis, raising the possibility that hypnotized
eyewitnesses may be more vulnerable to leading questions and other postevent
misinformation effects. Even when no new memories are produced, the popular

Cultic Studies Journal, Vol. 14, No. 2, 1997, page 41
belief in the efficacy of hypnosis may lead shaky eyewitnesses to become more
confident in whatever it is that they do remember. (p. 739)
This view is demonstrably false. If there are instances where the use of hypnosis does not
contaminate memory, then their thesis must fail. In fact, there are many appellate cases
where either (1) the forensic hypnosis sessions produced no deviations from recorded
prehypnosis statements, or (2) the deviations are independently corroborated. For example,
the South Carolina Supreme Court, in its opinion in State v. Evans (1994), recites the usual
list of dangers with hypnosis, but the court nevertheless finds no memory contamination
and independent corroboration or the hypnotically recalled details. State v. Evans does not
stand alone. As Karlin and Orne are aware, dozens of appellate cases reach these same
conclusions: that no new or different memories resulted from the hypnosis, or that
hypnotically refreshed recollection was independently corroborated (Raginsky, 1969).
2. Hypnosis does not always produce accurate recall.
Karlin and Orne echo other false memory writers when they claim that (1) hypnosis does
not always produce accurate recall, and (2) it is not possible to tell which parts of
hypnotically refreshed recollection are accurate and which are not. Karlin and Orne are
correct, but their target is really memory, not hypnosis. As Kihlstrom (1993b) has observed,
no memory carries with it its own stamp of authenticity. We cannot know, regardless of the
retrieval technique, which memory is true and which is false. To say that hypnosis is
unreliable because a memory elicited in hypnosis may be true or false is to fail to condemn
all other retrieval techniques on precisely the same grounds. Once again, the problem here
is with memory, not hypnosis.
It is sometimes claimed that hypnosis is unreliable because there is no research which
shows an increase in accuracy of memory with hypnosis. But there are studies that show
that when hypnosis is used properly, additional accurate information may become available
(Brown et al., 1997). Are there any memory retrieval techniques which always show
increased accuracy? There are none. Many studies, if not most studies, are instructive on
how to avoid excessive contamination they do not otherwise address increased accuracy.
The Karlin and Orne view, that hypnosis should never be used with memory because it
inevitably contaminates memory, is thus unsupported by the science, the cases, and sound
policy. The Wisconsin Supreme Court, in State v. Armstrong (1983), permitted hypnotically
refreshed recollection to be introduced into evidence provided that certain safeguards are
met. The trial judge must review the hypnotic session to determine whether the hypnosis
has unduly tainted the memory. The court‟s analysis, which avoids the Karlin and Orne error
of confusing hypnosis with memory, is exactly correct: “There are no experts who can
testify as to what specific effects hypnosis has had on the witness „memory just as there
are no experts who can testify that a normal waking memory of an event is in fact a
completely accurate representation of what accurately occurred. The most a trial judge can
do is review the hypnotic session to ensure that no impermissible suggestiveness has
occurred” (p. 393).
The Existence of Repressed Memory
On page 44, the authors continue their criticism of therapy by stating that many therapists
believe that “psychogenic amnesia” commonly follows traumatic stress. The authors then
claim that this idea has “little scientific support.” The scientific facts, however, prove
otherwise. First, the DSMBIV has replaced the term “psychogenic amnesia” with the term
“dissociative amnesia,” and I will use that more appropriate designation. Second, and more
important, is the fact that every study conducted on the subject, all of which are relevant to
the guidelines suggested by false memory proponents Pope and Hudson (1995a, b), has
documented dissociative amnesia in cases of childhood sexual abuse. Scheflin and Brown