Cultic Studies Journal, Vol. 14, No. 2, 1997, page 48
Therapists were instructed to be “open to the emergence of memories of trauma which are
not immediately available to the client‟s consciousness” (p. 25), but also alert to the
possibility of therapeutic suggestion. When a patient reports a memory, “it is important for
the therapist not to form premature conclusions about the truth status of a recovered
memory” (p. 24).
The Kentucky Attorney General‟s Final Report of the Task Force on Child Sexual Abuse
(1995) also validates repressed memory:
The recent creation of the False Memory Syndrome Foundation has brought public
and media attention to the controversy over whether memories of child sexual
abuse reported by adult survivors are valid. In reviewing this issue, the Task Force
looked at research studies which revealed that up to 60% of child sexual abuse
survivors report incomplete, or a total absence of, abuse-specific memories at
some point after victimization. Research has also shown that this type of delayed
recall is often associated with more violent and terrorizing cases of abuse.
While the high standard of evidence required by due process has questioned the
credibility of testimony based on delayed recall of abuse memories, these questions
should result in additional research and case law, but should not serve to invalidate
the actual experience of any abuse survivor. (p. 10)
Karlin and Orne move on to a related set of premises by rejecting claims that memories for
traumatic events are stored differently in the brain from other emotional memories and that
they emerge “unscathed through the mists of time” (p. 44). Once again, the science fails to
validate their opinions. There is now available substantial evidence from the biochemical
and neurological memory literature that traumatic memories are stored and retrieved
differently in the brain from other memories (Bowman &Mertz, 1996 Bremner, Krystal,
Charney, &Southwick, 1996 Brown et al., 1997 van der Kolk, McFarlane, &Weisaeth,
1996).
On the issue of the accuracy of these emerging memories, Loftus and Yapko (1995) observe
that as of 1993, “there have been no studies specifically demonstrating the validity of
repressed memories of childhood abuse that return in adulthood (Brewin, Andrews, &
Gotlib, 1993)” (p. 178). As of mid-1997, however, there are two available studies in the
world on this point, and they both conclude --contrary to the Karlin and Orne and the
Loftus and Yapko positions --that so-called traumatically repressed memories are no less
accurate than memories continuously and always remembered (Dalenberg, 1996 L. M.
Williams, 1995).
Thus, as a matter of science, contrary to the Karlin and Orne belief system, dissociative
amnesia is a real phenomenon recognized in every study and acknowledged by most of the
major mental health organizations. Meanwhile the Karlin and Orne view has no scientific
support and, given the absence of such support, their claims might not even qualify as a
“respectable minority” position.
In fact, in a recent letter from Pamela Freyd, Executive Editor of the FMSF, to the New York
Times (P. Freyd, 1997), objection is taken with the view that the FMSF “seeks to brand
most recovered memories as fabrications.” Instead, the FMSF:
has sought to bring to public attention the fact that when memories are
“recovered” with the use of techniques such as hypnosis, sodium amytal, dream
interpretation, participation in survivor groups and reading suggestive literature,
those memories are not necessarily reliable. The FMS Foundation has stated since
its inception that some memories are true, some a mixture of fact and fantasy and
some are false --whether the memories are continuous or remembered after being
forgotten.

Cultic Studies Journal, Vol. 14, No. 2, 1997, page 49
Theories about memory are fascinating and important. The current problem,
however, is discriminating true from false memories.
I agree with Freyd that the real issue is the accuracy of any memory, no matter how it is
retrieved. I also agree that memories long unavailable to the person, whether “forgotten” or
“repressed,” may also be accurate. The L. M. Williams (1995) and Dalenberg (1996) studies
demonstrate that repressed memories are no less accurate than continuous memory.
Thus, because all studies show that for some significant subset of the population of sexually
abused children, accurate memories of the abuse may not become available for a
substantial period of time after the abuse ended (Brown et al., 1997 Scheflin &Brown,
1996), courts and legislatures should (1) accept the legitimacy of repressed memories, (2)
recognize that repressed memories are not more accurate because they are repressed, but
they are not less accurate either, (3) acknowledge that the only true test of the accuracy of
any memory is independent corroboration, and (4) adopt the view that any method of
memory retrieval should be examined for undue suggestion under a “totality-of- the-
circumstances” test. I have no quarrel with the Utah Supreme Court‟s reasoning in Olsen v.
Hooley (1993) that, as a tactical matter for accusers who want to win recovered memory
cases, some corroborative evidence will be necessary to shift the burden of proof in their
favor:
It is common knowledge that memory is not only elastic but malleable, thus raising
the possibility that revived memories, even if true, are not entirely accurate....
Moreover, questions may be raised with respect to therapeutic methodologies used
to revive memories because they may induce memories of events that never
happened. The concern with respect to the reliability of memories revived in
therapy is a matter of some scholarly debate....
Because of concerns about the reliability of memory in general to events that
occurred long ago, apart from repression, and the difficulty of defending against
claims of revived memories of sexual abuse, we think it necessary to require that a
plaintiff who alleges repression of memory as a basis for tolling the statute of
limitations produce corroborating evidence in support of the allegations of abuse.
The Iatrogenesis Accusation: Memory and Suggestion
The difficulties with the Karlin and Orne analysis are further compounded when the authors
move, beginning on page 44, to their description of “iatrogenically created remote
memory.” Even they acknowledge that their depiction “includes extremes” (p. 48), but the
whole characterization is in fact a straw man for several reasons. First, their lament against
“recovered” memory must be put in perspective. By definition, and quite obviously, every
memory is “recovered” --that is what it means to be a memory. Second, there is no official,
authorized, recognized or legitimated “school” of “recovered memory therapy.” There are no
professional conferences on this subject, there are no journals for this therapy, and there
are no professional listings for “recovered memory therapy or therapists.” Where one sees
references to “recovered memory therapy” is in the literature distributed by false memory
proponents who initially coined the term for pejorative purposes and now, having repeated
it enough, have come to believe it is real. Karlin and Orne‟s depiction is a composite
nightmare of bad therapy, but it is not an accurate portrayal of a recognized, existing school
of treatment. It would be identically unfair to attack therapy because some therapists
unethically have sex with their patients, or to condemn hypnosis because some professors
of psychology use it to seduce students. I do not doubt that there are therapists who do
some of the things described by Karlin and Orne, and perhaps a few might come close to
doing all of them but these therapists do not practice a legitimate form of therapy. Rather,
they are performing below the recognized standard of care. Every profession unfortunately
has its share of incompetents. The mental health associations do not support the practices