Memory, Abuse, and Science - Questioning Claims about the False Memory Syndrome Epidemic

NOTE: This article is the award address for the American Psychological Association's Award for Distinguished Contributions to Public Service. It was published in American Psychologist, vol. 51, no. 9, pages 957-974.  The American Psychological Association owns the copyright.

ABSTRACT: Careful assessment of purported scientific discoveries and the resulting interpretations is a responsibility of every scientist. The area of memory, particularly memory for abuse, has recently seen new, highly publicized claims. These include the proposal of a new diagnostic category, the false memory syndrome; claims about the ease with which extensive autobiographical memories can be implanted; and estimates of the extent therapists use risky practices likely to cause false memory syndrome. This article suggests questions to evaluate these claims and the methods used to promote them. Implications for clinical standards and malpractice are discussed.

When scientific discoveries, evidence, and conclusions are announced, how do psychologists assess their validity? Uncritical acceptance of scientific claims may be as damaging as reflexive rejection. Science, policy, and education suffer when the vigorous authoritative promotion of claims fails to meet vigorous critical examination.

This article's approach is not to provide a simplified set of supposed answers or support a sense of certitude but rather to suggest that an essential task of psychologists is careful, informed, and comprehensive questioning. They must question their own assumptions, biases, and perspectives, not just once during initial training, but throughout their careers. They must also question claims about scientific discoveries, evidence, and conclusions, no matter how prestigious or popular the source. This article reviews some relatively recent claims about false memories and suggests types of questions that psychologists may find useful in evaluating these and other claims.

Complex factors may shape the process by which announced discoveries and conclusions encounter or elude careful scrutiny. Such factors include prevailing scientific paradigms, historical contexts, and the bandwagon effect. They can influence the degree to which people are inclined, willing, and free to question certain claims. These factors are themselves a legitimate and important focus of scientific questioning.

A relatively recent set of claims hold that many therapists-for reasons as diverse as well-meaning naiveté, greed, incompetence, and zealotry-suggest a history of childhood sexual abuse to clients who have no actual abuse history. According to the claims, clients who uncritically accept these suggestions and come to believe illusory memories of abuse with great conviction, suffer from an iatrogenic disorder termed false memory syndrome . This psychopathology, which according to Kihlstrom (1996) resembles a personality disorder, has allegedly manifested sufficient numbers of cases to reach epidemic proportions. In the short span of time since the 1992 founding of the False Memory Syndrome Foundation (FMSF), claims about false memory syndrome -- a condition that the Foundation identified and named-and related phenomena have had a profound impact on issues germane to ethical and competent psychological science and practice. FMSF noted its own "success" as reflected in the "institutionalization of this information in psychology text books, in reference works, in novels, in television dramas, and in hundreds of scholarly papers" (P. Freyd, 1996). The American Psychological Association (APA) approved FMSF as a provider of continuing education programs for psychologists ("American Psychological Association Approves, " 1995). The false memory syndrome concept is addressed in appellate decisions (e.g., State v. Warnberg , 1994). [Footnote 1] Herman (1994) and Landsberg (1996a, 1996b) are among those who have noted the popular media's frequently uncritical acceptance of these claims.

Although it is unusual that a lay advocacy group could produce adequate scientific evidence to support its discoveries and claims, FMSF highlights the contributions of its Scientific and Professional Advisory Board. FMSF emphasizes not only that "board members make substantial donations to the Foundation both in time and money" but also that "it is the presence of the Advisory Board that has given our efforts credibility" ("FMSF Advisory Board Meeting," 1993, p. 3). The FMSF Scientific and Professional Advisory Board includes distinguished and prominent members in the fields of psychology, psychiatry, sociology, and cognitive science (FMSF, 1996a). Their contributions of time, money, reputations, and credibility to the goals and work of FMSF may represent a significant if not crucial factor in the Foundation's success. The Scientific and Professional Advisory Board's implicit endorsement of the false memory syndrome diagnosis may help explain why such FMSF claims are so vividly reflected in the professional literature, expert testimony, and the popular media. If widely accepted, claims about a false memory syndrome epidemic traced to therapeutic malpractice may influence diagnosis and treatment for many people; the access or lack of access that individuals have to various services; and the clinical, forensic, and public response to those who report memories of childhood abuse (K. S. Pope & Brown, 1996).

This article's purpose is twofold. First, it suggests questions that may be useful for evaluating the evidence that purportedly established the validity of claims about false memory syndrome and their policy implications. Second, it proposes that scholarly examination of some methods used to promote these claims (e.g., diagnosis and characterization of those who disagree) might reveal factors influencing the degree to which these claims are critically examined. Are the methods used to promote these claims creating a context in which such claims are unlikely to be examined critically, freely, and comprehensively?

Review of the Literature: Memory Theory Prior to the False Memory Syndrome Foundation and False Memory Syndrome

The notion that psychology tended to view memory as a near-perfect recording device until the last several years finds no historical support. A review of the literature reveals a long history of exploring how-rather than whether-memory could be fallible, malleable, and suggestible. Psychology's fascination with memory's imperfections dates back at least to the founding of the APA, which provides a vivid example. Writing a history of the Association's first 38 years, Fernberger (1932) described the memorable meeting on July 8, 1892, among APA organizers Stanley Hall, George Fullerton, Joseph Jastrow, William James, George Ladd, James Cattell, and Mark Baldwin. A decade later, he described his attempts to verify accounts of that meeting, including his contacting of two of the alleged participants (Cattell and Jastrow), both of whom denied having attended. He concluded, "There is really no evidence that the meeting was ever actually and physically held" (Fernberger, 1943, p. 35).

Two years before this supposed meeting, William James (1890) wrote the following:

False memories are by no means rare occurrences in most of us. Most people, probably, are in doubt about certain matters ascribed to their past. They may have seen them, may have said them, done them, or they may only have dreamed or imagined they did so. The most frequent source of false memory is the accounts we give to others of our experiences. Such accounts we almost always make both more simple and more interesting than the truth. We quote what we should have said or done rather than what we really said or did; and in the first telling we may be fully aware of the distinction. But ere long the fiction expels the reality from memory and reigns in its stead alone. This is one great source of the fallibility of testimony meant to be quite honest. It is next to impossible to get a story of this sort accurate in all its details, although it is the inessential details that suffer most change. (pp. 373-374)

(Müensterberg's (1908) studies of how people imperfectly remember experimentally staged events, Bird's (1927) demonstration of how postevent information can influence recollection, and Barlett's (1932) analysis of how telling a story from memory (as in the game of "gossip" or "telephone") reveal distortions are but a few examples of the rich and diverse history of research in this area.

The fallibility of memory and even perception itself, which furnishes so much of memory's content, resulted in part from their creative action. Long before (Hubel and Wiesel (1962a, 1962b, 1979) investigated the neurophysiological construction of perceptions, Koffka (1935) reviewed extensive studies of how stimulus properties, contextual forces, and observer variables could bring forth misperceptions such as Wertheimer's (see Boring, 1929) "phenomenal movement" (or "phi-phenomen"), the classic optical illusions, and the phantom limb phenomenon. The mind did not passively receive and store perfect perceptual representations; it actively constructed representations of varying correspondence with external events and continued to work on the constructions. In rejecting the static, passive, storehouse model of perception, memory, and mind, Koffka (1935) emphasized

what a strange store-house we find it to be! Things do not simply fall into those places into which they are being thrown, they arrange themselves in coming and during their time of storage according to the many ways in which they belong together. And they do more; they influence each other, form groups of various sizes and kinds, always trying to meet the exigencies of the moment. (p. 518)

He concluded that "we are in full agreement with Barlett, who says: 'In fact, if we consider evidence rather than presupposition, remembering appears to be far more decisively an affair of construction rather than one of mere reproduction'" (p. 656). The mind, memory, and perception have each emerged this century not as "static, not a large storage bin nor a passive blank slate [but rather as] an organ of activity, process, and ongoing work" (K. S. Pope & Singer, 1978a, p. 106; see also K. S. Pope & Brown (1996); K. S. Pope & Singer, 1978b, 1980).

False Memory Syndrome: Claims of a Scientifically Validated Syndrome and Epidemic

Memory's imperfection provides a context for the FMSF's claims about the supposed syndrome it appeared to discover and helped to institutionalize. According to proponents of this reputed new syndrome, sufficient cases have been diagnosed to constitute an epidemic. These claims of a mental health epidemic provide an opportunity to consider questions that can be useful in evaluating purported scientific discoveries, evidence, and conclusions.

The definition of false memory syndrome found in the literature published by the FMSF was written by John Kihlstrom, who has served as an FMSF Scientific and Professional Advisory Board member. The current FMSF brochure repeats this description of

the False Memory syndrome -- a condition in which a person's identity and interpersonal relationships are centered around a memory of traumatic experience which is objectively false but in which the person strongly believes. Note that the syndrome is not characterized by false memories as such. We all have memories that are inaccurate. Rather, the syndrome may be diagnosed when the memory is so deeply engrained that it orients the individual's entire personality and lifestyle, in turn disrupting all sorts of other adaptive behaviors. The analogy to personality disorder is intentional. False Memory Syndrome is especially destructive because the person assiduously avoids confrontation with any evidence that might challenge the memory. Thus it takes on a life of its own, encapsulated, and resistant to correction. The person may become so focused on the memory that he or she may be effectively distracted from coping with the real problems in his or her life. (Kilhstrom, 1993; Kihlstrom, 1998, p. 16; also quoted in FMSF, 1995)

Ceci, Bronfrenbrenner, Eckman, and Shepard were among 17 researchers who coauthored a statement objecting to the term false memory syndrome as "a non-psychological term originated by a private foundation whose stated purpose is to support accused parents." They urged, "For the sake of intellectual honesty, let's leave the term 'false memory syndrome' to the popular press" (Carstensen et al., 1993, p. 23).

Methodology for Determining That Memories Are Objectively False

Several questions may be useful in assessing the scientific validity of these diagnostic features. First, how did the researchers, clinicians, or others who validated this syndrome determine in each case that the memory was "objectively false?" Those claiming that scientific research has validated false memory syndrome and identified an epidemic have a responsibility to disclose the methods for determining that each case involved a memory that was objectively false. The peer-reviewed scientific literature still lacks adequate information about this methodology.

It remains unclear whether the protocol of any research purporting to validate the false memory syndrome diagnosis in large numbers of persons used any criterion other than the decision rule that all recovered memories of abuse are inherently false. Statements by some FMSF proponents have seemed to characterize recovered memories of trauma as objectively false per se. FMSF Scientific and Professional Advisory Board member Harrison Pope and his colleague James Hudson (1995a; see also 1995b) emphasized that "traumatic experiences are memorable" (p. 715), asserted that there has never been a confirmed case of "noncontrived amnesia among neurologically intact individuals over the age of 6 who experienced events sufficiently traumatic that no one would be expected to simply forget them" (p. 716), [Footnote 2] and asserted that trauma survivors in scientifically valid studies "unanimously remembered the events" (p. 715). Founding FMSF Scientific and Professional Advisory Board members Hollida Wakefield and Ralph Underwager (1994) [Footnote 3] wrote, "People who undergo severe trauma remember it" (p. 182). Scientific and Professional Advisory Board member Martin Gardner (1993) asserted that

better-trained, older psychiatrists do not believe that childhood memories of trauma can be repressed for any length of time, except in rare cases of actual brain damage. And there is abundant evidence that totally false memories are easily aroused in the mind of a suggestible patient. (p. 374)

FMSF (1992b) itself published the claim: "Psychiatrists advising the Foundation members seem to be unanimous in the belief that memories of such atrocities cannot be repressed. Horrible incidents of childhood are remembered" (p. 2).

In light of the evidence put forward to establish their validity, it is important to examine the claims that human memory systems process significantly traumatic experiences differently from other stimuli-for example, that sufficiently traumatic experiences are always available to awareness; are never subject to such varying constructs as forgetting (see Feldman-Summers & Pope, 1994), amnesia, dissociation, or repression; and thus can never be subject to recovered memory.

Other questions emerge when examining claims about the diagnosis of false memory syndrome and the supposed epidemic. If there are validation studies for false memory syndrome and the epidemic that do not reflexively judge all reports of recovered memories of abuse to be objectively false, what was the research methodology for determining whether the reports were objectively true or false? Does the methodology yield an acceptable rate of false positives and false negatives? Assuming more than one person made each judgment, what was the interrater reliability? How was the methodology itself validated?

Until the methodology and raw data used in identifying and validating the syndrome and verifying sufficient cases to constitute an epidemic are adequately disclosed, it may be helpful to consider the methods and evidence that proponents have set forth to determine whether memories of abuse are objectively false. One proposed set of criteria for distinguishing between objectively true and false memories of abuse focuses on the reactions of the person who experienced the memories. FMSF (1994) published a newsletter article entitled "How Does a Person Know That Memories of Abuse Were False?" based on a study of an unspecified number of people who experienced such memories, later decided the memories were false, and subsequently retracted their claims of having experienced abuse. Indicants of false memories included failure to find corroborating evidence, memories described by retractors "as not 'feeling' like other memories" (FMSF, 1994, p. 3), and "the change in their life since they came to this realization" (i.e., "Many describe a sense of peace and comfort with their decision that their memories were false and a sense of well-being that they missed while entrenched in the memory recovery process"; p. 4).

A second set of criteria for distinguishing true and false memories of abuse emerged from a study of what was described as "a representative sample of families who had contacted the FMS Foundation" (de Rivera, 1994, p. 149). [Footnote 4] Seven criteria were set forth as appearing to identify false memories. Among these indicants were: "There are no such memories prior to therapy, " "The accused has no history of any pedophiliac tendencies and there is no evidence of any sexual interest in children, " and "The accused and the family are willing to openly discuss the allegations and explore them for logical coherence" (de Rivera, 1994, p. 154).

A third set of indicants was set forth by Pamela Freyd, who is currently FMSF executive director, in an article entitled "How Do We Know We Are Not Representing Pedophiles?" (1992b). Two methods were presented as ways to show that the memories forming the basis of accusations against members are false:

There are two ways that we will address this concern. The first has to do with who we are. If I had taken a camera to any of the three meetings held here in Philadelphia, I would have been hard put to know whom to photograph. We are a good looking bunch of people: graying hair, well-dressed, healthy, smiling. The similarity of the stories is astounding, so script-like and formulaic that doubts dissolve after chats with a few families. Just about every person who has attended is someone you would likely find interesting and want to count as a friend. The second way that we will address this concern involves lie detector tests. If all members of the FMS Foundation either have had or express a willingness to be polygraphed, we will have a powerful statement that we are not in the business of representing pedophiles. (p. 1)

Such assertions in support of claims about reliably separating true and false reports of child abuse may or may not be persuasive to the media, clinicians assessing child abuse accusations, the courts, or others, depending on a variety of circumstances. However persuasive they may seem, such claims are best examined in light of such questions as, is there adequate scientific research to support the claims? Similar claims, such as clinicians' assertion that they can, on the basis of certain profiles or criteria, reliably and validly determine whether an individual is capable of engaging in sex with a child, benefit from a careful examination of the scientific evidence demonstrating such clinical abilities. In Legal Aspects of False Memory Syndrome, FMSF (1992b) informed its members that some "psychiatrists will opine that, in their opinion, a particular individual is not a pedophile and perhaps would not or could not have performed the acts complained of" (p. 2). Regardless of whether courts may admit such statements as evidence that a recovered memory of childhood sexual abuse is "objectively false, " psychologists have an obligation to examine the scientific bases supporting such assessments.

Claims about valid, reliable identification of false memories of child abuse or of false accusations based on these false memories deserve and require careful evaluation in light of evidence and logic. For example, if self-reports of abuse memories are to be doubted in the absence of external "proof," why are self-reports about retracted memories presented as presumed valid in the absence of external verification? What scientific evidence supports claims that such factors as good looks, dress, health, and smiling serve as valid and reliable indicants of whether or not an individual has engaged in child abuse?

Methodology for Assessing an "Entire Personality and Lifestyle"

Having determined that the memory was objectively false, how did those who validated false memory syndrome assess whether that false memory actually "orients the individual's entire personality and lifestyle?" Assessing whether there are aspects of the individuals' personality or lifestyle that remain consistent and unchanged (i.e., not oriented to the objectively false "memory") would present a considerable challenge even to the most skilled and experienced clinicians. Disclosing the methodology for making this determination would allow careful examination of the assumptions, evidence, and reasoning that support the research and encourage replication and additional research into false memory syndrome.

Claims of False Memory Syndrome's Similarity to Personality Disorders

It is not clear how similar this new disorder is to the recognized personality disorders to which it is explicitly analogized, or whether this analogy simply makes explicit the notion that the same sort of severe pathology presumed present in the classic personality disorders is present in the alleged false memory syndrome. The Diagnostic and Statistical Manual of Mental Disorders (4th ed.; DSM-IV ; American Psychiatric Association, 1994), for example, states that

a Personality Disorder is an enduring pattern of inner experience and behavior that deviates markedly from the expectations of the individual's culture, is pervasive and inflexible, has an onset in adolescence or early adulthood, is stable over time, and leads to distress or impairment. (American Psychiatric Association, 1994, p. 629)

Does defining false memory syndrome to resemble recognized personality disorders imply that onset does not occur beyond early adulthood? Does it suggest that, whereas the syndrome becomes manifest in adulthood, its foundation-like the foundation of recognized personality disorders-rests on earlier weaknesses or dysfunction in the individual? Wakefield and Underwager (1994), for example, noted that "Gardner sees the women who make false allegations based on recovered memories as very angry, hostile, and sometimes paranoid. He believes that all will have demonstrated some type of psychopathology in earlier parts of their lives" (p. 333). The Philadelphia Inquirer quoted Wakefield's description of those who recover memories: "The adult children who 'remember' sexual abuse decades after they say it happened are 'not just anybody. They are women who already have problems, such as personality disorder, and they're likely to be unusually suggestible' " (Sifford, 1991, p. 12).

Thousands of Empirically Documented Cases

Within about a year of the founding of FMSF, which identified and named a new syndrome, proponents began to claim that the syndrome was widespread. FMSF Scientific and Professional Advisory Board member Martin Gardner (1993) wrote that among the purposes of the FMSF was "to seek reasons for the FMS epidemic" (p. 375). In the process of researching the problem, FMSF made the following statement:

FMSF is first a research organization that is documenting the extent of this phenomenon. There is a standard procedure that is followed for phone interviews. We currently have in our files hundreds and hundreds of "Maybe's." Maybe's are names that are given to us as families that are affected by false memory syndrome but for whom we do not have the standard documentation information. Unless we have complete and standard documentation, we do not add these people to the count of affected families. (FMSF, 1993, p. 7)

Two of the founding Scientific and Professional Advisory Board members cited as validating evidence for false memory syndrome "the empirical data the FMS Foundation has from 12, 000 families" (Wakefield & Underwager, 1994, p. 98).

The FMSF's (see Wakefield & Underwager, 1994) research evidence allegedly

points with high certainty towards a false memory syndrome that meets the requirements for a syndrome contained in the DSM-III-R and the DSM-IV. The thousands of instances that contain those common elements are likely to be more support for this syndrome than for any other that has been accepted as a legitimate classification category. (p. 99)

Expert witnesses, therapists, policy makers, reporters, the courts, graduate courses, and continuing education programs could thus cite a growing literature accepting and helping institutionalize the notion that false memory syndrome was not only a scientifically validated disorder caused by psychotherapy, but that the number of documented cases was exceptionally large. For instance, Goldstein and Farmer (1993) asserted, "Now we know that False Memory Syndrome is an iatrogenic disease created by therapy gone haywire. We know that false memory syndrome has reached epidemic proportions" (p. 9). By 1996, FMSF distributed an information sheet and order form (for its video False Memory Syndrome) in which it claimed that "False Memory Syndrome [is] a devastating phenomenon that has affected tens of thousands of individuals and families worldwide" (1996b).

It would be helpful for FMSF and its Scientific and Professional Advisory Board to describe the research protocols or other formal procedures by which false memory syndrome has been adequately validated as a syndrome and by which it was determined that it has affected tens of thousands of individuals and families. Clearly stating such operationalized procedures as how reported memories of abuse are found to be "objectively false" in any study that documents the widespread nature of false memory syndrome allows the independent analysis, verification, and replication that is the hallmark of psychological scientific empiricism. It is possible that the impressive names, prestige, offices, and affiliations of the Scientific and Professional Advisory Board may have, however unintentionally, led fellow scientists, the courts, the popular media, and others to accept without customary skepticism, care, and examination of alternative hypotheses the methodology and arrays of primary data relevant to the notion of false memory syndrome and other FMSF assertions as scientifically validated.

It is worth emphasizing that some therapists engage in incompetent, unethical, or well-meaning but misguided behaviors, sometimes with disastrous consequences for patients (see, e.g., K. S. Pope, 1990, 1994; K. S. Pope, Simpson, & Weiner, 1978). In some instances, these behaviors include using unvalidated, misleading, or bizarre methods for assessing whether a patient was sexually abused as a child (K. S. Pope & Vasquez, 1998). However, such facts alone are insufficient basis for claims that there "is an iatrogenic disease created by therapy" and that this "false memory syndrome has reached epidemic proportions" (Goldstein & Farmer, 1993, p. 9). The scientific evidence that supposedly validates claims about this so-called syndrome, its causes, and its epidemic proportions needs to be made available and carefully examined.

Informed-Consent Issues in Research Validating False Memory Syndrome

Research involving human participants usually involves the informed consent of the participants. For those independently evaluating or attempting to replicate studies seeming to validate the existence and widespread occurrence of false memory syndrome, it would be useful if the procedures for obtaining informed consent-if consent was obtained-from people who were diagnosed as suffering from false memory syndrome were disclosed. It appears possible, on the basis of a reading of materials generated by the FMSF, that some might not consider interviewing or clinically assessing the people supposedly afflicted by false memory syndrome to be an essential component of a study of the validity and occurrence of the syndrome. If, for this reason, the informed consent of or even direct contact with people diagnosed with false memory syndrome has been considered unnecessary in documenting specific cases or the extent of the phenomenon, it would be useful for FMSF and its Scientific and Professional Advisory Board to report any available scientific data about the ability to diagnose false memory syndrome without meeting the person alleged to have the disorder. If the person reporting the so-called memory does not participate in the research, how do researchers conclude that the memory is objectively false (rather than simply subjectively judged to be false by those who have been accused)? How do researchers determine that the center of a person's identity and interpersonal relationships is a particular false memory without even meeting the person? How do they examine all aspects of personality without interviewing, evaluating, or even knowing the person?

Independent Examination of the Primary Data and Methodology

Independent examination of the primary data and methodology used to establish the validity and reliability of a new psychological diagnosis, prior to its application to large numbers of people, is an essential scientific responsibility. Diagnoses lacking validity may attract proponents if distorting influences like confirmation bias, illusory correlation, and false consensus have not been eliminated from the validation studies and subsequent use. However, once set forth as a scientifically valid, established, and institutionalized category, a readily diagnosed formal psychological syndrome gains immense power to influence others. As Rosenhan wrote,

Such labels, conferred by mental health professionals, are as influential on the patient as they are on his [sic] relatives and friends, and it should not surprise anyone that the diagnosis acts on all of them as a self-fulfilling prophesy. Eventually, the patient himself [sic] accepts the diagnosis, with all of its surplus meanings and expectations, and behaves accordingly. (1973, p. 254; see also L. S. Brown, 1995b; Langer & Abelson, 1974; Mednick, 1989; Murphy, 1976; K. S. Pope, Butcher, & Seelen, 2000; Reiser & Levenson, 1984)

The Cause of False Memory Syndrome: Trauma Memories Implanted in Therapy

To exaplain why people who had never been abused would accuse parents or others of sexually abusing them, false memory syndrome proponents have tended to assert that therapists implanted the memories. For example, FMSF (1995) claimed "that certain psychotherapeutic techniques, theories and practices have led many people to falsely believe they were sexually abused as children" (p. 1). Seeking research evidence that specific therapist behaviors cause harm poses a dilemma: Investigators cannot randomly assign patients to conditions hypothesized to cause injury. Typically, studies attempt to correct for the absence of random assignment by selecting appropriate comparison groups, by matching patients on relevant variables, and by using measures that are likely to create maximum sensitivity and specificity to the phenomenon at issue. For example, research assessing whether therapists' sexual behaviors were associated with specific patient symptoms might compare a group of patients who had engaged in sex with a therapist with matched (in regard to demographics, etc.) groups of patients who had not engaged in sex with a therapist and of patients who had engaged in sex with a physician who was not a therapist (for reviews of such research, see K. S. Pope, 1994; K. S. Pope, Sonne, & Holroyd, 1993). In this instance, researchers have tended instead to attempt demonstration that false memories of events described as traumatic can be implanted in other contexts, with generalizations from these findings to what must occur in psychotherapy.

Loftus's widely cited experiment in which older family members apparently implanted memories in 14-year-old Chris, 8-year-old Brittany, and three other participants has been claimed as the "proof" (Loftus & Ketcham, 1994, p. 99) that implanting traumatic memories is possible. When challenged with the assertion, "But it's just not possible to implant in someone's mind a complete memory with details and relevant emotions for a traumatic event that didn't happen, " Loftus responded: "But that's exactly what we did in the shopping mall experiment" (Loftus & Ketcham, 1994, p. 212). Proponents described this experiment as demonstrating the creation of an extensive false memory. (Lynn and Nash (1994) reported that "Loftus and Coan were able to implant an extensive autobiographical memory" (p. 198). (Lindsay and Read (1994) claimed that "Loftus and Coan demonstrated that people can be led to create detailed and extended 'recollections' of childhood that never occurred" (p. 289). The popular press echoed a similar theme arguing, for example, that the most practical significance about the lost-in-the-shopping-mall study is that "it buttresses an alternative explanation for the source of recovered memories that True Believers purport to have repressed. Namely that the memories have been implanted by some type of suggestion; they are false" (Boss,1994, p. 12).

Among the kinds of questions that might be useful in evaluating claims about implanting "a complete memory with details and relevant emotions for a traumatic event that didn't happen" based on this research are the following:

• Does the trauma specified in the lost-in-the-mall experiment seem comparable to the trauma forming the basis of false memory syndrome? Loftus (1993) described the implanted traumatic event in the shopping-mall experiment as follows: "Chris was convinced by his older brother Jim, that he had been lost in a shopping mall when he was five years old" (p. 532). Does this seem, for example, a reasonable analogy for a five-year-old girl being repeatedly raped by her father? Pezdek (1995; see also Pezdek, Finger, & Hodge, 1996) has suggested that this may not be the case. In attempting to arrive at a more analogous situation-that of a suggested false memory of a rectal enema-her experimental attempts at implantation of a suggestion had a 0% success rate.
  
• What is the impact of the potentially confounding variables in claiming the shopping-mall experiment to be a convincing analogue of therapy (Loftus, 1993; Loftus & Ketcham, 1994)? Is it possible that the findings are an artifact of this particular design, for example, that the older family member claims to have been present when the event occurred and to have witnessed it, a claim the therapist can never make? To date, replications and extensions of this study have tended to use a similar methodology; that is, either the older family member makes the suggestions in his or her role as the experimenter's confederate, or the experimenter presents the suggestion as being the report of an older family member, thus creating a surrogate confederate.
  
• Has this line of research assumed that verbal reports provided to researchers are the equivalent of actual memories? Spanos (1994) suggested that changes in report in suggestibility research may represent compliance with social demand conditions of the research design rather than actual changes in what is recalled. In what ways were the measures to demonstrate actual changes or creations of memory representations validated and confounding variables (e.g., demand characteristics) excluded? Given that being lost while out shopping is apparently a common childhood experience, how is the determination made that the lost-in-the-mall memory is not substantially correct? What supports the claim that "Chris had remembered a traumatic episode that never occurred" (Garry & Loftus, 1994, p. 83). That is, is there any possibility that Chris's family had forgotten an actual event of this type?
  
• If the experiment is assumed for heuristic reasons to demonstrate that an older family member can extensively rewrite a younger relative's memory in regard to a trauma at which the older relative was present, why have false memory syndrome proponents presented this research as applying to the dynamics of therapy (e.g., Loftus, 1993; Loftus & Ketcham, 1994) but not to the dynamics of families, particularly those in which parents or other relatives may be exerting pressure on an adult to retract reports of delayed recall? Is it possible that older family members can rewrite younger relatives' memories in regard to traumatic events at which they were present? Might this occur in the context of sexual abuse when the repeated suggestion is made by a perpetrator that "nothing happened" and that any subsequent awareness of the abuse constitutes a false memory?

This line of research has been extended by others, and similar research has been carried out in varied designs (e.g., "false memories" of words that did not appear in a list of words, suggestions of earaches and trips to the hospital at night, suggestions of rectal enemas). [Footnote 5] One crucial question is, does this research adequately justify the claims that are being made in legal cases and elsewhere? An FMSF (1995) amicus curiae brief (which includes a list of the 47 prominent members of the FMSF Scientific and Professional Advisory Board as an appendix) presented a typical claim: "Memories of truly traumatic events are easily altered and false recollections, though felt to be actual memories of real events, can easily be induced by suggestion" (p. 20).

Loftus (1992) published claims that are even more sweeping:

If handled skillfully, the power of misinformation is so enormous and sufficiently controllable that a colleague and I recently postulated a not-too-distant "brave new world" in which misinformation researchers would be able to proclaim: "Give us a dozen healthy memories and our own specified world to handle them in. And we'll guarantee to take any one at random and train it to become any type of memory that we might select regardless of its origin or the brain that holds it." The implications for the legal field, for advertising, and for clinical settings are far reaching. (p. 123)

These expansive a claims echo those made by Watson (1939) over a half century ago, when a line of behavioral research led to claims that the power of learning theory was so enormous and sufficiently controllable that psychologists with sufficient resources could take individuals at random and produce any kind of people and behavior they might select. If there was a lesson to be learned from the Watsonian claim, it was modesty. Not only did human beings fail to fall helplessly under the power of conditioning, docile animals often refused to act in accordance with the proclaimed principles of the new science (e.g., Breland & Breland, 1961). It was the rush to uncritically embrace claims that went far beyond the data--the failure to question carefully--that caused the Watsonian fall.

Therapists as Perpetrators of False Memory Syndrome

An additional assertion with regard to false memory syndrome has been the claim that significant numbers of therapists engage in behaviors likely to iatrogenically inflict the false memory syndrome. Lindsay and Poole (1995), for example, stated, "In our view there are solid grounds to fear that tens of thousands of people have developed illusory memories or false beliefs about CSA [child sexual abuse] through suggestive memory recovery techniques and ancillary practices in psychotherapy, self-help, or group therapy" (p. 464). In a study to examine clinical practices, Poole, Lindsay, Memon, and Bull (1995) reported data from a study of both U.S. and British clinicians and suggested that their findings indicated that

25% of the members of those organizations who conduct psychotherapy with adult female clients believe that recovering memories is an important part of therapy, think they can identify clients with hidden memories during the initial session and use two or more techniques to help such clients recover suspected memories of CSA. (p. 434; initial findings from Poole et al.'s study were previously presented and discussed in an article by (Lindsay & Read, 1994)

(Lindsay and Read (1994) "refer to such approaches collectively as 'memory recovery therapies'" (p. 282), "are sharply critical of the memory recovery techniques" (p. 298), and fear "that these powerful techniques are being used in ways that are damaging the lives of many clients and their families" (p. 282). They compare memory recovery therapy "to a powerful medicine that may be helpful to victims of a disease but that can cause great harm when given to people who do not have the disease" (p. 282). They claimed that the self-report of a constellation of beliefs (i.e., recovering memories is an important part of psychotherapy and therapists thinking they can identify clients with hidden memories) and practices (i.e., use any two of a list of techniques in the last two years) constitutes a "grave risk" (p. 327).

Others besides the study's authors have cited the results as providing evidence that so-called memory recovery therapies are commonly practiced by psychotherapists and that many therapists are at risk of harming clients by engaging in such behaviors. For example, an FMSF (1995) amicus curiae brief claimed that "recent surveys of therapists' understanding and practices have shown a number of widely held misconceptions, which if communicated to patients, may increase a client's responsiveness to suggestion-and in turn, [lead] to the development of false memories" (p. 5).

FMSF Scientific and Professional Advisory Board member Dawes (1995) characterized the techniques included in the study as "coercive techniques" (p. 12). Loftus (1995) claimed "that these activities can and do sometimes lead to false memories seems now to be beyond dispute" (p. 24). In addition, Loftus, Milo, and Paddock (1995) used Poole et al.'s (1995) data to estimate that as many as 25% of clinicians "may be using techniques that are risky if not dangerous" (p. 304). Because they use some techniques included in Poole et al.'s list, specific therapists have been publicly labeled as "dangerous." For example, the Jerusalem Post reported opposition to Utrecht University psychology professor Onno van der Hart's plan to lecture in Israel on his treatment of adults who suffered childhood abuse:

Members of the US False Memory Syndrome Foundation and psychologists in various parts of the world charged that van der Hart and his colleagues were "very dangerous." His critics charged that van der Hart's techniques represented a "harmful and unscientific method of pseudotherapy that must be seen as a threat to psychology in Israel. This 'therapy' makes the patient dependent on the therapist by inventing multiple personalities, false memories and accusations, which have already destroyed tens of thousands of families in the US." (Siegel-Itzkovich, 1996, p. 7)

Poole et al.'s (1995) study has also been 491 used as the basis for various estimates of the frequency with which illusory memories of abuse may occur. Pendergrast (1995) estimated that "25% of doctoral level therapists constitute True Believers" (p. 491; a discussion of True Believers appears later in this article) and that "over one million cases of 'recovered memories' each year" (p. 491)--allegedly illusory ones--occur in psychotherapy in the United States. Using similar calculations, FMSF Scientific and Professional Advisory Board member (Crews (1995) claimed that "it is hard to form even a rough idea of the number of persuaded clients a conservative guess would be a million persons since 1988 alone" (p. 160). Dawes (1995) estimated a lower bound of 1,475,833 women who, in the last two years, had seen therapists who reported using two or more techniques specified in Poole et al.'s survey to help individuals recover memories. Thus, Dawes concluded that "Wakefield and Underwager are absolutely correct in their assessment that recovered memory therapy is widespread" (p.12).

Olio (1995a, 1995b, 1996) suggested, however, that such conclusions might not be valid. She formulated questions about the research design, statistical tests, and inferences that might be useful in evaluating this study, among which are the following four:

1) Did the survey construction lead to confounded results?

Olio (1996) noted that the critics of recovered memories have repeatedly emphasized the thesis that memory may be particularly susceptible to distorting or confabulating influences when responding to questions (especially related to the past) or giving self-reports. Ironically, this study relies on similar data-gathering procedures in which people are asked numerous questions based on their memory of past complex events. (Poole (1996) herself acknowledged that the data "do not necessarily index what clinicians do in their offices because they are retrospective self-report measures" (p. 1).

The study failed to use free-recall questions. For example, rather than asking, "Do you use any memory-recovery techniques, and if so, what are they?" Poole et al. (1995) used a potentially suggestive technique of the type they criticized therapists for using. Participants were first told that other "therapists use special techniques to help clients remember childhood sexual abuse" (Poole et al., 1995, p. 430) and then were provided a list of techniques to check. Olio (1996) suggested that in light of current theory on memory, recall, and the impact that questioning may exert on responses, the use of these techniques may have unintentionally shaped the findings to confirm the beliefs of false memory syndrome proponents.

2) Do the measures have face validity?

According to Olio (1996), the conclusions of (Poole et al.'s (1995) study are based on the unproven assumption that clinicians with certain (self-reported) beliefs practice differently from clinicians with other beliefs and that these differences in practice create greater risk for the production of illusory memories. She questioned this assumption that beliefs are reliable predictors of behaviors. The complex chain of assumptions (i.e., reported belief to actual belief to behavior to consequences for patients) may be questionable at best. For example, Polusny and Follette (1996) found that despite therapists' beliefs about the prevalence of repressed memories, the majority of therapists holding these beliefs reported that they had not seen any cases of adult clients who entered therapy with no memory of childhood sexual abuse and subsequently recalled abuse during therapy.

Poole et al. (1995), according to Olio (1996), apparently drew inferences about implanting or creating illusory memories of childhood abuse in clients who reported no memories of childhood abuse at the beginning of psychotherapy and who did not in fact have an actual history of childhood abuse. Unfortunately, key questions in the survey did not inquire specifically about the use of various therapy techniques with this particular population. The questions used were

Survey 1: "Some therapists use special techniques to help clients remember childhood sexual abuse. Check any technique that you have used with abuse victims in the past 2 years."

Survey 2: "Check on the left ["tick" for the British survey] any technique that you have used in the past 2 years to help clients remember childhood sexual abuse." (p. 430)

The question on Survey 1 specifically asked about techniques used with "abuse victims" and did not inquire how many (if any) of these were clients who denied abuse, but whom the clinician suspected might have had abuse histories. Similarly, the inquiry regarding techniques used to "help clients remember childhood sexual abuse" in Survey 2 did not differentiate between techniques used with clients who reported a history of abuse (both those with continuous or accessible memory and those who recovered memories of abuse prior to psychotherapy) and techniques used with clients who denied such a history.

Olio (1996) suggested that other inconsistencies between the actual survey questions used and the reported conclusions may be important. For example, Poole et al. (1995) claimed that "25% believe that recovering memories is an important part of therapy" (p. 434), whereas the actual survey question asked respondents to rate "how important is it 'that a client who was sexually abused acknowledges or remembers [italics added] the abuse in order for the therapy to be effective'" (p. 430). Poole et al. (1995) suggested that their survey "indicates that some clinicians believe they can identify clients who were sexually abused as children even when those clients deny abuse histories" (p. 434). However, the survey question (in Survey 2) asked about instances in which the client did not explicitly report any abuse, not about instances in which the client denied abuse histories. Finally, Poole et al.'s (1995) claim that 25% "think they can identify clients with hidden memories during the initial session" (p. 434) is based on questions that asked (retrospectively), "Of adult female clients whom you suspected [italics added] were sexually abused as children what percentage initially denied any memory of childhood abuse" (p. 430; Survey 1) and asked if participants "had ever suspected [italics added] that a client had been abused although the client did not explicitly report any abuse" (p. 430; Survey 2). It seems that a clinician's acknowledgment that he or she sometimes had suspected an abuse history significantly differs from a belief that he or she could identify those with hidden abuse memories (see subsequent section Not Suspecting Child Abuse ).

3) Are the techniques risky?

Poole et al.'s (1995) characterization of potentially risky behaviors practiced by 25% of clinicians relied on a "constellation" of three self-report items (discussed previously): two items relating to beliefs and one to practice. Olio (1996) observed, however, that there are no validation studies for this constellation of reported beliefs and practice and therefore no way to determine what is actually being measured by these items, no way to determine what outcome(s) result from this constellation, and no way to know how the results might differ from other psychotherapy practices. According to Olio, the study apparently assumed that some techniques are risky per se, rather than recognizing that virtually all psychotherapy techniques have the potential for damage depending on the manner, context, and timing in which they are used.

Olio (1996) noted that Poole et al. (1995) did not offer any criteria or research to define what might constitute a risky frequency of use for the listed techniques. Despite expressing concerns regarding approaches to therapy "that combine several techniques in a prolonged search for suspected hidden memories" (Lindsay, 1995a, pp. 281-282), in Poole et al.'s data, the criteria for questionable practice is satisfied with the single use of any two techniques (even on a single occasion) during the last two years. Therefore, a therapist who allows one client to keep a journal and bring in family photos as a way of decreasing the anxiety and pain of the remembering process would be counted among those engaging in coercive, risky practices that can create false memories and would be classified as a potentially dangerous recovered-memory therapist.

Olio (1996) argued that in essence Poole et al. (1995) created an unvalidated checklist (for risky practices), not dissimilar to the unvalidated checklists of symptoms that Lindsay and Read (1994), among others, correctly criticized some clinicians for using to identify histories of childhood abuse. Responding to Olio's critique, Lindsay (1995b) conceded that he did "agree that there are far too little data to make firm statements about the prevalence of 'risky' memory work" (p. 1).

4) Did Poole et al. (1995) incorrectly infer causality?

Olio (1996) noted that Poole et al. (1995) claimed "our survey indicates these interventions can have serious implications for clients (e.g., lead some clients to terminate relations with their fathers)" (p. 434). This conclusion is based on responses to the following question: "Of the adult female clients who initially denied any memory of sexual abuse, what percentage came to remember childhood sexual abuse during the course of therapy?" (p. 431). Poole et al. reported that in "Survey I, we asked respondents to report the percentage of clients, among those who through therapy remembered abuse, who confronted their abuser and who cut off relations with the abuser" (p. 432).

Thus, all abuse reported by therapists as having been recalled during the course of therapy (Poole et al., 1995, p. 431) was claimed by the authors to represent cases of abuse remembered "through" therapy (p. 432). Olio (1996) observed that this is a form of the logical fallacy post hoc, ergo propter hoc ("after this, therefore on account of this"). Poole et al. committed this fallacy, according to Olio, with their claim that because therapists reported having used certain techniques and reported that some clients recovered memories during this time span, the techniques must have caused the memories. Furthermore, Poole et al. used this logic to claim that the use of those particular techniques had serious implications; that is, it was the use of those techniques that lead clients to terminate relations with their fathers. In both instances, presumed correlation is confused with causation.

Olio (1996) noted that such assumed correlations may be misleading. She used the example of a hypothetical survey in which respondents were asked if their patients got older during the course of therapy. Even if 100% of the therapists reported that their clients became older during therapy, it does not provide evidence that the aging process was attributable to or even differentially associated with therapy. Olio emphasized the importance of placing such data within a 2 x 2 (whether patients recovered memories by whether therapist used specified interventions) or similar model and of assessing whether randomization and other procedures were adequately considered. Such a statistical model would assess the relationships among (a) patients recovering memories during therapy as reported by therapists using specified interventions, (b) patients not recovering memories during therapy as reported by therapists using specified interventions, (c) patients recovering memories during therapy as reported by therapists not using specified interventions, and (d) patients not recovering memories during therapy as reported by therapists not using specified interventions.

Redefining Malpractice and the Standard of Care

The FMSF and its proponents have published claims not only about scientific findings but also about the nature of malpractice and the standard of care. Pending systematic surveys and other research addressing the issue, it is impossible to know the degree to which such published statements by a prominent organization or professionals may have a chilling effect on the professional services provided by therapists who disagree with these claims. What impact will clinicians' knowledge that prominent expert witnesses may testify that certain services constitute malpractice have on the availability of those kinds of services? As with claims of scientific findings, it is important to respond with neither reflexive acceptance nor rejection but rather careful questioning.

Should Therapists Be Required To Seek External Validation?

One set of claims asserts that without seeking external validation through family members or others, the therapist violates the legal standard of care by providing treatment when recovered memories of abuse are at issue. FMSF has highlighted in its publications such statements about the standard of care by its Scientific and Professional Advisory Board members as, "To treat for repressed memories without any effort at external validation is malpractice pure and simple" (McHugh, 1993b, p. 1; for an alternate view, see American Psychological Association Task Force on Violence and the Family, 1996, p. 74; K. S. Pope & Brown, 1996). FMSF (1992a) also published a statement, adapted from two Scientific and Professional Advisory Board members, of the 13 steps a therapist needs to take in regard to gathering external validating information when adult patients allege childhood sex abuse. The therapist of a person who has sought treatment for recovered memories of incest must not only contact the parents and seek other sources of validation but must also provide comprehensive information about the patient to clinicians working on behalf of the parents; to refuse to provide such information raises the question of an absence of "good faith" (McHugh, 1993a, p. 3).

Questions that might be useful in evaluating this claim include the following:

• Do FMSF proponents imply that therapists can accept without external validation reports based on memories that have been continuously accessible rather than recovered; that is, is there no legal mandate to seek external validation when an adult's memories of child sex abuse have been continuous?
• If so, what research findings support this distinction?
• Do FMSF proponents imply that therapists are legally required to seek external validation only when a patient reports child sex abuse; that is, is there no legal mandate to seek external validation for all patient reports of violence, abuse, crimes, or other such interactions?
• If so, what research findings support this distinction?

Behavioral and Pharmacological Therapies and Directing Feelings

Recent claims in this area address the kinds and content of therapy. (Loftus (1995) in the Skeptical Inquirer , for example, supported the development, evaluation, and use of "behavioral and pharmacological therapies that minimize the possibility of false memories and false diagnoses" and urged therapists to avoid "dwelling on the misery of childhood" (p. 28). Maintaining that patients are best served when therapists adhere to the following principles, Loftus wrote,

Borrowing from John Gottman's (1994) excellent advice on how to make your marriage succeed, patients might be reminded that negative events in their lives do not completely cancel out all the positives (p. 182). Encourage the patient to think about the positive aspects of life-even to look through picture albums from vacations and birthdays. Think of patients as the architects of their thoughts, and guide them to build a few happy rooms. The glass that's half empty is also half full. Campbell (1994) offers similar advice. Therapists, he believes, should encourage their clients to recall some positive things about their families. A competent therapist will help others support and assist the client, and help the client direct feelings of gratitude toward those significant others. (Loftus, 1995, p. 28)

Among the questions useful in carefully evaluating these claims are the following:

• Is there research demonstrating that behavioral and pharmacological therapies produce fewer false memories and false diagnoses than other forms of therapy?
• What evidence supports the claim that to be competent a therapist must render help to third parties in their efforts to support and assist a therapy client?
• What evidence supports the claim that to be competent a therapist must help clients to direct feelings of gratitude to third parties?

Not Suspecting Child Abuse

Claims that such factors as clothing, attractive appearance, smiling behavior, and chatting provide a reliable basis for concluding that a person has never engaged in child abuse stand in contrast to claims that presenting symptoms must never lead anyone to suspect that a person may have been sexually abused. For example, Kihlstrom (1995b; see also (Olio, 1995c) wrote that "it is not permissible to infer, or frankly even to suspect, a history of abuse in people who present symptoms of abuse." He similarly asserted that "you can never, never, never, never, never, infer a history of sexual abuse from the patient's presenting symptoms. Nevernevernevernevernevernevernevernevernevernever" (1995a). These claims taken together seem to suggest that although presenting "symptoms of abuse" never justify suspicion that a person was involved in child abuse, presenting factors such as clothing and appearance can reliably demonstrate that a person was not involved in child abuse.

In evaluating the effects of prohibiting suspicion of child abuse based on presenting symptoms, it may be useful to ask, how will it affect mandated reporting of suspected child abuse? Reviews of state laws suggest that almost 50% use a form of the verb "suspect" (e.g., "suspect that a child has been abused") in legislation requiring therapists to report suspected child abuse (Kalichman, 1993). Other states use similar concepts but different wording.

Another question for evaluating this prohibition is, to what degree if at all might therapists refrain from pursuing diagnostic leads based on presenting symptoms because of the threat of malpractice suits? Decisions to report suspected child abuse may be covered by at least a qualified immunity, but assessment and treatment actions generally are not. Without research data concerning the potential influence of this prohibition, it is impossible to know if or how it will affect clinicians' responses to presenting symptoms.

A third question useful for assessing this claim is, to what degree do various arrays of presenting symptoms lead at least some therapists to suspect child abuse as one possible event that may be associated with the symptoms and warrant consideration in the assessment process? Approaches to gathering relevant information might take a variety of forms such as presenting symptom arrays to clinicians and asking if they might lead to a suspicion of abuse. For example, a cluster of presenting symptoms for a young girl might include panic and avoidant behavior in the presence of her father; nightmares occurring every few hours that, according to the patient, involve a shadowy figure grabbing at her genitals; and refusal to allow a physical examination although she had previously allowed them during medical office visits. Clinicians might also be asked if the notion that chart notes or other evidence revealing that such presenting symptoms led them to suspect child abuse as a diagnostic possibility might subject them to a malpractice suit affected their responses to these symptoms.

Unacceptable Books and Ideas

In some instances published works condemned by FMSF proponents become targets of legal action. Lawsuits in two California cities blamed a book for leading people to believe false memories of childhood sex abuse ("Author Target of False-Memories Lawsuit, " 1994; Butler, 1994; K. S. Pope, 1995). A licensing complaint was filed against a therapist asserting "that an article she had written for a journal titled Medical Aspects of Human Sexuality could suggest false incest diagnoses" (Butler, 1995, p. 28).

Therapists may themselves face formal complaints for using books containing unacceptable ideas. The Philadelphia Inquirer , for example, quoted Paul Fink, a past president of the American Psychiatric Association, saying on the topic of therapists who give The Courage To Heal: A Guide for Women Survivors of Child Sexual Abuse (Davis & Bass, 1994) and similar books to their patients: "There's a name for this--bibliotherapy. To give a book that espouses a narrow thesis of mental functioning is malpractice" (Sifford, 1992, p. D6).

Careful evaluation of such restrictions on the flow of ideas may include consideration of such questions as:

• At what point does a thesis of mental functioning become defined as sufficiently narrow that any book espousing it must be banned from therapy? For example, B. F. Skinner relegated so-called mental functioning to an unobservable epiphenomenon, irrelevant as a variable in the scientific study of human behavior. Would this thesis of mental functioning be considered sufficiently narrow that a behavior therapist giving one of Skinner's books to a client would be considered malpractice?
• Is it essential to the malpractice claim that the harmful ideas appear in the form of a published book? For example, if instead of giving the book to a patient so that the patient can study and form an opinion about the thesis himself or herself, the therapist were to say to a patient, "There is a book by Bass and Davis that espouses this view of mental functioning, " or otherwise discuss the ideas within the book, is that too malpractice?
• If it is malpractice for therapists to give such books to their patients, would it also constitute malpractice for supervisors to give such books to their therapy trainees, hospitals and clinics to make such books available in their libraries, professionals leading workshops to use them as texts, or professors to assign them to their students?
• How, if at all, does the prospect of encountering expert testimony that giving a particular sort of book to a patient is per se malpractice influence the behavior of therapists and the range of services, ideas, and choices available to those in need?

Checklists for Assessing Incompetence and Other Forms of Malpractice

Some FMSF proponents have created and endorsed checklists by which patients can supposedly determine whether a therapist is incompetent, is causing harm, or is engaging in other forms of malpractice. For example, an FMSF Scientific and Professional Advisory Board member noted that "whether or not a therapist has a doctoral degree, is irrelevant to his psychotherapeutic competence" (Campbell, 1994, p. 49) and published a 40-item checklist by which patients can supposedly assess a therapist's competence (p. 251). With minor revision, this instrument has been published by others (e.g., (Wakefield & Underwager, 1994). The number of "yes" responses supposedly indicates the likelihood that the therapist is "incompetent" and that the therapist is causing "much more harm than good."

The book, however, provides no references to published research establishing the validity, reliability, sensitivity, or specificity of this instrument. If there is a scientific basis for this instrument, it would be useful for the FMSF Scientific and Professional Advisory Board members endorsing it to provide those research data so that these claims can be carefully evaluated.

Careful Examination: The Scientific Process

Questioning scientific claims may be difficult if a prestigious group portrays them as the only legitimate scientific view, sufficiently established so as to preclude serious consideration of any alternative views. For example, a prominent regional psychological association invited an array of scientists to discuss the debate about memory and abuse from a scientific perspective. Suggestions that a more balanced program might be achieved by supplementing the members of the FMSF Scientific and Professional Advisory Board who had been invited as speakers with scientists who might present alternatives to the FMSF view were rejected by FMSF as unscientific. The False Memory Syndrome Newletter set forth the rationale for the rejection:

A memory researcher told us that research academics "don't even know what this memory debate is about. They see the evidence and to them the science of memory is obvious." He is right. The "science" of the "memory" is established. How could a scientific program about memory be "balanced?" The notion makes no more sense than trying to balance a program in astronomy by including astrologers. ("Social Political Movement," 1996)

As previously noted, the factors that can discourage careful questioning of scientific claims or consideration of alternate views are many. Scientists must be aware of these factors and must carefully and responsibly question claims and consider other explanatory models regardless of the prestige of those who might assert that a particular thesis about memory and abuse is beyond question.

Responsible scientific questioning of specific claims bears at least one similarity to conducting well-designed experimental research. Experimental research must attend not only to variables of primary interest but also to potentially confounding factors. Similarly, careful examination of reported scientific findings and principles must attend not only to central claims but also to potentially confounding factors that may influence the degree to which people are inclined, willing, or free to question or reject certain claims. This section examines such potentially confounding factors and their implications.

Picketing

Picketing therapists is a highly visible tactic. If therapists who disagree with certain claims, voice their disagreement, and behave in ways that are inconsistent with those claims fear that their patients may be forced to cross a picket line in order to obtain their services, it may affect the degree to which they feel free to carefully question and rationally consider these claims.

As early as 1992 in an FMSF newsletter article titled "What Can Families Do?" the tactic of picketing was discussed (FMSF, 1992c). FMSF members picketing therapists has emerged as a topic at professional conferences and in the literature of this area, sometimes including discussion of the experience of a therapist targeted for picketing (e.g., Brown, 1995a; Calof, 1996; see also Butler, 1995). Among questions that might be useful in evaluating the potential consequences and implications of this tactic are the following:

• What is the impact on patients who are forced to cross a picket line to obtain treatment from a provider of a particular form of legal health care service? Will patients choose to cross picket lines, forego treatment altogether, or pursue treatment from someone acceptable to false memory syndrome proponents who establish picket lines?
• Some patients or potential patients may perceive and value a right of privacy and believe it important that no one else know that they seek mental health services. Those wishing to seek treatment for concerns such as sexual abuse from family members, domestic violence, or torture may fear that, should the fact that they are seeking professional help become known, their own lives or the lives of their families might be endangered or that other negative consequences might occur (see, e.g., Calof, 1996; J. J. Freyd, 1996; Herman, 1992; Koss et al., 1994; K.S. Pope, 2001; K. S. Pope & Brown, 1996; K. S. Pope & Garcia-Peltoniemi, 1991; Salter, 1995). How does forcing patients to cross picket lines affect such privacy concerns?
• How do patients (or therapists) evaluate or anticipate what may happen to them should they cross through the picket line (do they believe it possible or likely that they will be followed, their license plate number taken down, their picture taken, and so on)? How do clients form opinions about what the pickets, FMSF, or others may view as justifiable steps to take when targeted services continue despite picketing? Butler (1995) quoted the FMSF executive director:

"If somebody came into your house and shot your child, it would probably be justifiable homicide if you did something, and that's how these parents feel, " says Freyd. "When you get between parents and children, you can expect things to happen." (p. 75)

Describing and Diagnosing Individuals Who Disagree

Diagnosing and otherwise categorizing those who disagree may influence the degree to which people are inclined, willing, and free to question scientific claims. When such diagnoses and categorizations are set forth, it is important to examine the scientific evidence on which they rest, their social or policy consequences, and their potential effects on scientific deliberations. Two founding members of the FMSF Scientific and Professional Advisory Board published an article examining why University of California, Los Angeles, professor Roland Summit and others persist in believing in child abuse phenomena that according to some claims are unscientific and absurd. They concluded that the cause of such beliefs among professionals lay not in the evidence for the hypotheses, nor in social or contextual variables, nor in differing perspectives, but rather in the relational dysfunctions or psychopathology of those who believe these ideas. Underwager and Wakefield (1991) wrote,

The answer to the question why do some professionals believe and not others is in the internal variables of the personalities of the believers. It ranges from factors that may make a person difficult to relate to but remaining functional to serious psychopathology. (p. 190)

Paranoid

Those disagreeing may be characterized more specifically as manifesting paranoid beliefs or responses. FMSF Scientific and Professional Advisory Board member Richard Ofshe wrote, "These responses signal the collective paranoia of a social movement turning inward" (Ofshe & Watters, 1993, p. 16). Another FMSF Scientific and Professional Advisory Board member explained, in an APA divisional presidential address, that the belief of "abuse-believers" frequently "takes on a paranoid cast" (Spence, 1993; see also Wakefield & Underwager, 1994, pp. 41-43).

Cult and sect.

The Washington Post quoted the FMSF executive director as characterizing those who work to open up the topic of sex abuse to public awareness as cult-like. " 'I can understand, ' says Freyd, 'people who are trying to open up the area of sexual abuse being infuriated by us. They feel we aren't helping their work. But they are a little like a cult' " (Sherrill, 1995, p. F1). Pendergrast (1995) recommended different terminology. "Some have called the Survivor Movement not only a religion, but a cult. It is all too easy to label any fervent group a 'cult, ' with all its negative connotations. I prefer the word 'sect' " (p. 478). This characterization addresses the motivation of certain therapists who disagree:

Most of the therapists appear to be True Believers on a mission. That fits Hassan's general observations: "They believe that what they are doing is truly beneficial to you. However, they want something more valuable than your money. They want your mind! Of course, they'll take your money, too, eventually." Similarly, trauma therapy guarantees a protracted period of recovery and, hence, a steady income. (Pendergrast, 1995, p. 479)

True Believers.

One of the most commonly used labels to describe individuals who disagree with the FMSF is True Believer . Loftus used the concept of True Believer to support her claim that resistance to her work is based not on evidence, reason, and good faith but rather prejudice and fear (e.g., "I know the prejudices and fears that lie behind the resistance to my life's work"; (Loftus & Ketcham, 1994, p. 4). She split the profession into two groups. Identifying herself as a skeptic, she and her colleague wrote,

On one side are the "True Believers, " who insist that the mind is capable of repressing memories and who accept without reservation or question the authenticity of recovered memories. On the other side are the "Skeptics, " who argue that the notion of repression is purely hypothetical and essentially untestable, based as it is on unsubstantiated speculation and anecdotes that are impossible to confirm or deny. (Loftus & Ketcham, 1994, p. 31)

Loftus makes clear her source by quoting from Hoffer's (1951/1989) well-known text, The True Believer.

If the skeptic demands proof, how does the True Believer decide what to believe in? Hoffer (1951/1989) observed that True Believers shut themselves off from facts, ignoring a doctrine's validity while valuing its ability to insulate them from reality (p. 80). Hoffer (1951/1989) described the True Believer's passionate hatred and fanaticism, noting "the acrid secretion of the frustrated mind, though composed chiefly of fear and ill will, acts yet as a marvelous slime to cement the embittered and disaffected into one compact whole" (p. 124). Among the most prominent professionals who are True Believers, according to the false memory literature, are psychologists Judith Alpert, Laura Brown, and Christine Courtois, three members of the APA working group on recovered memories. (Pendergrast (1995) wrote, "The American Psychological Association has created a six-person committee to study the repressed-memory issue. Three of the members are experimental researchers who are skeptical of massive repression, including Elizabeth Loftus. The other three are True Believer therapists." (pp. 503-504; see also Wakefield & Underwager, 1994, p. 349). The term True Believers characterizing those who disagree now appears in the peer-reviewed scientific literature, for example, in an article by a member of the FMSF Scientific and Professional Advisory Board (Crews, 1996, p. 66 ).

Use of Holocaust imagery.

Those who disagree with FMSF have also been compared to Fascists. In her book Diagnosis for Disaster: The Devastating Truth About False Memory Syndrome and Its Impact on Accusers and Families , Wassil-Grimm (1995) , for example, used the imagery of the Holocaust, explicitly referring to Hitler and the Jews: "Hitler had the Jews; McCarthy had the communists; radical feminists have perpetrators" (p. 91). The Oregonian quoted the FMSF Executive Director Pamela Freyd as describing the behavior of professor Jennifer Freyd as "Gestapolike" (Mitchell, 1993, p. L6), a term she had previously used in a journal article (Doe, 1991, p. 155) [Footnote 6] later reprinted as a book chapter (Doe, 1994, p. 29). Another use of imagery related to the Holocaust, used on this occasion to compare an FMSF Scientific and Professional Advisory Board member to those who risked their lives to save Jews from the Nazis, appeared in the Boston Globe: " 'I feel like Oskar Schindler, ' Loftus muses, referring to the German financier who rescued doomed Jews from the Nazis. 'There is this desperate drive to work as fast as I can'" (Kahn, 1994, p. 80).

It is important to examine the use of imagery related to the Holocaust to compare explicitly or implicitly one who disagrees to Hitler, the Gestapo, and Nazis or to portray an FMSF proponent as engaged in a desperate rescue. Among questions to be addressed in careful examination of this use are the following: Do such statements reflect on the motivation, character, and decency of those who disagree with FMSF claims? Do such statements promote a climate of hate and hostility toward those who fail to accept FMSF claims? Do such statements have a chilling effect on some who otherwise might voice questions about FMSF claims? How might such statements affect the scientific and popular (e.g., media) evaluation of FMSF claims about the difficult and complex issues of remembering child sex abuse?

Obtaining and Revealing Disclosures to Therapists

According to the Portland Oregonian, FMSF director Pamela Freyd recommended tactics to learn about someone else's therapy: "Follow your child to the office, hire a private detective, pry the information from other relatives your child may talk to, pose as a patient yourself" (Mitchell, 1993, p. L1; see also FMSF, 1992c, p. 4; Loftus, 1993, pp. 529-530). Finding out and revealing what people have said to their therapists has placed communications to therapists about alleged child abuse in a new context. In The Myth of Repressed Memory: False Memories and Allegations of Sexual Abuse, (Loftus and Ketcham (1994) reprinted quotes from a Playboy article (Nathan, 1992) that were apparently verbatim statements by women who were meeting with therapists as part of a four-day "retreat for survivors of sexual abuse, physical abuse, emotional abuse and neglect" (p. 202). The Playboy article's author was an investigative journalist who had attended the retreat for survivors and therapists. Among the questions that may be useful in evaluating the potential impact of such efforts to reveal disclosures about alleged abuse to therapists are the following:

• Does knowing about such published accounts affect the decisions of those who view themselves as having experienced sexual abuse, physical abuse, emotional abuse, and neglect about whether to seek services in group settings?
• Do the accounts of people's disclosures to therapists accord them basic respect and dignity? For example, The Myth of Repressed Memory: False Memories and Allegations of Sexual Abuse used such characterizations as the following to describe women talking with therapists about abuse: "Soon it was time to plunge into the gory details. A veritable competition began as one woman after another related her grisly stories, progressively upping the ante of horror" (Loftus & Ketcham, 1994, p. 203). FMSF has helped popularize what appears to be ridicule of those who claim to be abuse survivors through publication of such articles as "Whining About Abuse Is an Epidemic" (Nethaway, 1993, p. 6). Research could be useful in exploring whether the manner in which disclosures to therapists about alleged abuse are characterized in books, newsletters, and other works by FMSF proponents has any influence on the willingness of those who view themselves (accurately or inaccurately) as survivors of various forms of abuse to seek professional help.
• Do those who make such disclosures to therapists have concerns about the uses to which their statements may be put? Would they fear that their statements might be used in legal actions to deprive them of their civil rights, that is, that their statements would be construed as evidence of false memory syndrome, rendering them unable to make their own decisions? In "Legal Aspects of False Memory Syndrome, " for example, FMSF (1992b) informed parents that they "may take the legal position that the accusing child is incompetent and seek guardianship proceedings" (p. 3).
• Do these data-gathering activities and publications impose specific informed-consent duties on therapists? Do patients have a right to know that other patients, clerical or support staff, shelter volunteers, or others present may actually be detectives, reporters, and so forth, and that what they say in the presence of these other people may be published or put to use in other ways? Are patients who believe that they are talking to therapists or other helpers aware that in certain circumstances they may find their words quoted, even with a pseudonym. Pseudonyms may not prevent recognition of a specific individual (see, e.g., K. S. Pope, 1995). Is it possible that the information gathered may be used in a way patients would not have chosen or given consent for? If informed consent and informed refusal are fundamental rights of those seeking health care services, and if the consent process involves telling potential patients about factors that might reasonably affect their decision to consent to or refuse treatment (Caudill & Pope, 1995; K. S. Pope & Brown, 1996; (K. S. Pope & Vasquez, 1998), it is difficult to imagine any legitimate justification for withholding information about such possibilities from those who will be most affected. This is an important question of professional responsibility and public policy and deserves careful and comprehensive discussion.

Conclusion

Claims about a new diagnostic category (false memory syndrome) reaching epidemic proportions, the ease with which extensive autobiographical memories about trauma can be implanted, and the large number of therapists engaging in behaviors likely to cause false memories of trauma in their patients deserve careful consideration.

It is important to examine carefully the evidence and logic of the claims and to ask, what if these claims are valid? The profound implications for individual lives, public policy, the standard of care, clinical work, and education and training have been compellingly set forth in books by Crews (1995), Dawes (1994), Goldstein and Farmer (1993, 1994), Loftus and Ketcham (1994), Ofshe and Watters (1994), (Underwager and Wakefield (1994), and (Wassil-Grimm (1995) .

An open, fair, and independent analysis must also allow for the possibility that the evidence and logic do not convincingly establish the validity of some or perhaps any such claims. Psychologists must be prepared to examine the profound implications for individual lives, public policy, the standard of care, clinical work, and education and training if these widely accepted and institutionalized claims are invalid. What if, for example, tens of thousands of individuals have been wrongly diagnosed with a label lacking adequate scientific validation?

It is equally important to examine the process by which these claims are evaluated and institutionalized, including tactics used to promote them. Psychologists must be as attentive to factors that, however unintentionally, may confound the process of consideration and discussion as they are to factors that may confound an individual experiment. If disagreement with certain claims is determined to reflect impaired functioning or serious psychopathology, the scientific process may be subverted. If those who question, doubt, or disagree are authoritatively characterized by professionals as hate-filled True Believers, paranoid cultists, or Hitler-like zealots, the process of free and independent analysis of FMSF claims may be affected. If patients currently seeking legal health care services from those who question or disagree with FMSF are forced to cross picket lines to obtain those services, if the privacy of their therapy is invaded, or if they are diagnosed without their participation as suffering a false memory syndrome, then their freedom of choice may be affected.

Claims grounded most firmly in the scientific tradition are those emerging from hypotheses that are falsifiable. Scientists bear an essential responsibility to examine primary data, research methodology, assumptions, and inferences. Science works best when claims and hypotheses can be continually questioned. That which tends to disallow doubt and discredit anyone who disagrees is unlikely to foster the scientific venture or promote public policies and clinical practices based on scientific principles. Each scientific claim should prevail or fall on is research validation and logic.

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Footnotes

Footnote #1: Legal determinations that allegations of sexual abuse are false because the witness suffers from false memory syndrome generally require expert testimony. The appellate ruling in State v. Warnberg (1994), for example, described a set of facts in which "sexual assault occurred when Warnberg pulled the car to the side of the road to allow the complainant to be sick, at which time she claimed he approached her from behind, undid her bra, and fondled her breasts while she was vomiting Warnberg sought to introduce evidence of a sexual assault against the complainant thirteen years prior to the alleged assault. He argued that that evidence was relevant to his contention that the complainant's accusation was the result of a psychologically displaced or repressed memory or 'false memory syndrome.' The trial court rejected Warnberg's proposed evidence on the ground that it could not determine from Warnberg's offer of proof that such a syndrome existed. Warnberg argues that the trial court should have granted his motion for a continuance to allow him to produce an expert who could testify to the validity of the false memory syndrome. A concept such as false memory syndrome requires an expert witness to testify to its existence." (Back to body one)

Footnote #2: H. G. Pope and Hudson (1995a) did not claim that child sexual abuse per se is never forgotten. They asserted that children may actually undergo what a majority of adults would identify as sexual abuse "but the experience may not seem particularly traumatic or strikingly memorable to the child" (p. 716). Their general argument rests on such premises as the absence of proof is equivalent to proof of absence. They asserted that questioning such premises does not reflect sound reasoning: "It might be argued that absence of proof is not proof of absence; the lack of evidence for repression does not refute its existence. But this argument is flawed" (p. 718). (Back to body two)

Footnote #3: Underwager is no longer listed as a member of the FMSF Scientific and Professional Advisory Board. (Back to body three)

Footnote #4: The sample consisted of nine families. The methodology for selecting the sample was as follows: "In order to select a representative sample of families who had contacted the FMS Foundation, the investigator chose a telephone area code and contacted all families within that code who met [certain] criteria" (de Rivera, 1994, p. 149). (Back to body four)

Footnote #5: For discussions of this and related lines of research from diverse perspectives, see Bowman and Mertz (1996); (Brewin, Andrews, and Gotlib (1993); D. Brown (1995a, 1995b); J. J. Freyd and Gleaves (1996); Hyman, Husband, and Billings (1995); (Koss, Tromp, and Tharan (1995); Loftus and Pickrell (1995); Pezdek et al. (1996); (Roediger and McDermott (1995); Westen (1996); Whitfield (1995); and Zaragoza and Koshmider (1989). (Back to body five)

Footnote #6: In late February 1992, when she wrote that she was "going to serve as Executive Director of the FMS foundation, " Pamela Freyd confirmed in the False Memory Syndrome Newsletter that "You already know me as Jane Doe" (Freyd, 1992a, p. 1). (Back to body six)

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