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traumatization will suffer memory distortion and impairment (American Society of Clinical
Hypnosis, 1995 Brown et al., 1997).
For example, substantial memory disturbances were found in some survivors of traumas
such as earthquakes (Cardena &Spiegel, 1993), concentration camp experiences (Chodoff,
1963 Kinzie, Sack, Angell, Clarke, &Ben, 1986 Krell, 1993 Strom et al., 1962), pipeline
explosions (Realmuto, Wanger, &Bartholow, Jr., 1991), rapes (Rothbaum, Foa, Riggs,
Murdock, &Walsh, 1992), building collapses (Wilkinson, 1983), ethnic cleansing in war
(Weine et al., 1995), and lightning strikes (Dollinger, 1985). These studies were not
primarily focused on memory, but they all reported memory deficits in a substantial part of
the populations studied. Interestingly, Dollinger (1985) found that 2 of the 38 children
studied after watching lightening strike and kill a playmate had no memory of the event
and Weine et al. (1995) noted that some of the Bosnian refugees fleeing from “ethnic
cleansing” “demonstrate a profound capacity for not knowing about traumatic events that
they have reportedly experienced. Not yet 1 year after the war, some refugees question
whether or not it happened at all” (p. 51).
One final semantic point. The concept of “forgetting” in common parlance is a generic term
that includes all forms of not remembering, including repression, dissociation, amnesia, and
so on. Therefore, it is not unusual for people who cannot recall to say they forgot. But the
mechanisms for being unable to recall may be very different. In some instances, it may be a
retrieval problem, while in others it may be an encoding or a storage problem. Technically,
however, repression is different than ordinary forgetting and Pope and Hudson (1995a, b)
have identified an important difference: traumas not likely to be forgotten may be
repressed.
The Doe court‟s conclusion that severe childhood sexual abuse sustained over a long period
of time was merely “forgotten,” and therefore was not worth legally recognizing, violates
common sense, laboratory science, and human compassion.
Even without this scientific data, before many of the studies had been reported, some major
mental health professional associations had recognized the concept of repressed memory.
For example, the American Psychiatric Association (1993) “Statement on Memories of
Sexual Abuse” specifically notes:
Children and adolescents who have been abused cope with the trauma by using a
variety of psychological mechanisms. In some instances, these coping mechanisms
result in a lack of conscious awareness of the abuse for varying periods of time.
Conscious thoughts and feelings stemming from the abuse may emerge at a later
date.
Similarly, the American Psychological Association‟s (1996) Final Report from the Working
Group on Investigation of Memories of Childhood Abuse acknowledges that “it is possible for
memories of abuse that have been forgotten for a long time to be remembered” (p. 1). As
noted by Presiding Judge Dalianis in State v. Walters (1995):
Finally, even Dr. Loftus conceded upon cross-examination that the APA policy
which she helped to create notes that “it is possible for memories of abuse that
have been forgotten for a long time to be remembered.”... The language of the
APA report indicates that the challenge to recovered memories which is included
therein concerns the mechanism by which the delayed recall occurs, rather than
the fact of its occurrence.... Furthermore, Dr. Loftus acknowledged that dissocia-
tion from a traumatic event is a recognized phenomenon. (pp. 23-24)
Judge Dalianis found further proof of the existence of repressed memories from the
testimony of Dr. Hudson, who stated that repression is not generally accepted in the

Cultic Studies Journal, Vol. 14, No. 2, 1997, page 47
scientific community. On cross-examination, however, Hudson proved himself to be
unfamiliar with the scientific literature. According to Judge Dalianis:
The court is persuaded by the results of studies, elicited upon cross-examination of
Dr. Hudson, that Dr. Hudson‟s statement that no studies evidence the phenomenon
of traumatic repression is incorrect....
In addition to the fact that the majority of experts and the recent studies evidence
that traumatic amnesia is a recognized phenomenon, the general acceptance of the
phenomenon is evidenced by the fact that it has been referenced in psychological
works and studies for over one hundred years. Finally, the fact that traumatic
amnesia is referenced in the Diagnostic and Statistical Manual utilized by all
experts in the area of psychiatry and psychology persuades the Court that it is an
acknowledged phenomenon. (pp. 24-26)
The American Medical Association Report of the Council on Scientific Affairs entitled
“Memories of Childhood Abuse” (1994) considers the view that repressed memories do not
exist to be “extreme.” The report cites studies showing that there are cases where amnesia
for childhood sexual abuse exists because the “recovered memories proved to be correct”
(p. 3).
The most thoughtful report was issued by the British Psychological Society (1995) because
the report was based on thorough research and investigation. Significantly, the Society
considered the false memory position on repression to be an “extreme position” (p. 6) and
preferred to discuss the available scientific evidence for traumatic amnesia. The Society
concluded that “forgetting of certain kinds of trauma is often reported” (p. 14) for very
different kinds of trauma ranging from war trauma to childhood sexual abuse. The available
evidence suggests between one third and two thirds of people have periods of time when
they “totally or partially forgot the abuse” (p. 13). Regarding the evidence for false beliefs
of childhood sexual abuse, the report drew a distinction between incorrect memories (event
actually happened but some details are incorrectly remembered), false memories (event
never happened), and false confessions. While “a great deal of evidence” is available about
incorrectly remembering details, there is “much less evidence on the creation of false
memories” (p. 29). Scientific evidence for the common occurrence of misremembered
details about actual experiences (memory fallibility) cannot be used to support claims about
false memories.
Turning to memory suggestibility, the report concluded that individuals who are highly
suggestible, and less suggestible individuals in response to waking suggestions by
“authority figures” or to hypnotic suggestions, may create false memories (p. 14). The
report clearly cautions, however, that there is little evidence that “a few suggestive
questions in therapy” lead to false memories. The phenomenon of false memories is
different from forensic data on false confessions in that false memories are believed and
retained over long intervals, while false confessions extracted through interrogation are not
believed and are not stable. The report significantly concludes by stating that (1) “there is
no reliable evidence at present that this [false memory] is a widespread phenomenon” (p.
3) and (2) the claim that false memories are largely a product of a therapist‟s rigid beliefs
about abuse in patients who do not present with abuse is not substantiated by the facts.
As a final point, the report also investigated the data on accusers and alleged offenders
collected by the British False Memory Society, because many of the hypotheses about
therapeutic suggestion of false memory were derived from these data. The reporters
discovered, contrary to claims of false memory advocates, that only about one fourth of the
accusers reported to have recovered memories after a period of total amnesia. Therefore,
there was no solid evidence to support the claim that alleged false memories are primarily
created in psychotherapy.