By Dr Grant J. Devilly MAPS
Professorial Fellow, Brain Sciences Institute, Swinburne University

Grant Devilly specialises in reactions to traumatic experiences, resilience and the treatment of anxiety disorders. Working with victims of crime, he also acts as an expert witness in court cases.

Repressed memory 
False Memory Syndrome
The case of Jane Doe

Few topics in psychology have crossed the professional boundary to become part of the everyday lexicon like that of 'false/recovered memories'. As psychologists we are commonly asked by the laity at social gatherings: "What's the story with recovered memories?". As we prepare our response and nervously flicker our eyes across the room - weighing our audience - the answer has already been delivered.

Adult children accusing parents of hitherto unmentioned childhood sexual assault causes mixed emotions in every corner of our society. Who would want to disbelieve, and so disenfranchise, someone so maltreated by one that should have been a carer rather than abuser? Yet, who would want to accuse a denying parent of such a horrid crime without any evidence or history of consistent accusation? Of course, there are support groups for both sides of such a scenario - groups who would definitely take a side. And, in my view, it is appropriate that both sides of such a scenario receive support, but is it correct that both sides receive validation? To answer this question I believe we need to understand the science (or, rather, the scientific arguments) around this issue and, to place this in context, we start with a brief history of the issue, the terms used and its rise into common parlance.


Repressed memory

The idea that memories could be 'repressed' has been a prevalent theme with episodic popularity since Freud (On the etiology of hysteria) originated the term 'repression'. This was part of Freud's Seduction Theory, whereby he initially viewed psychological distress as having its roots in childhood sexual abuse. Freud himself later came to reject this notion, instead arguing that the psyche could not differentiate between imagined and real childhood sexualised behaviour. Instead Freud continued to develop his theories surrounding the id, ego and superego - theories that some people still believe in today. However, although this notion of 'repressed memories' has intermittently raised its head as a psychological spectre since the beginning of the 20th century, it was not until the 1980's that the current furore reached into the mainstream of society.

Many definitions of the term 'repressed memory' have been offered over the years and I do not intend to add to people's ire by providing yet another. However, recovery of a repressed memory is supposed to be a true recollection of an event that has become inaccessible to the individual with normal remembering. The key here to this whole debate (or 'war' as some have referred to it) is the term inaccessible.

On one side we have research teams headed by people such as Jennifer Freyd, Anne DePrince, Frank Putnam and Ross Cheit who claim that some experiences are so distressing to a child, and that child has so few resources left to them, that the memory is locked away in the psychic equivalent of a radioactive bunker. This bunker protects the individual from such a toxic memory and allows them to go about their everyday lives - although this perspective does advocate for the 'leakage' of symptoms being indicative of a possible (or, even, likely) abuse history. People such as Jennifer Freyd argue that an abused child has conflicts of interest (centred around a betrayal of trust) - on the one hand s/he is being abused and on the other s/he must rely upon the abuser for shelter and welfare. They argue that with limited resources the child 'represses' this memory by somehow sending it to the aforementioned metaphorical bunker. Termed 'Betrayal Trauma Theory', Anne DePrince and Jennifer Freyd have been experimentally testing the tenets of such a hypothesis (e.g., see DePrince & Freyd, 2004). These researchers basically argue that dissociative tendency mediates such a process and that people who score highly on dissociation (and there's an even longer running dispute as to what this term means) have a greater proclivity to 'repress' trauma-related material. It is argued that this 'repressed' material can, nevertheless, exert psychic distress and that, through specialised treatment strategies, the attending client can (or must) be brought to remember these past instances of abuse so that the healing process can begin in earnest. The most notable online resource for this perspective is the Recovered Memory Project (Cheit, 2007) hosted by Brown University.

On the other side, we have researchers such as Elizabeth Loftus, Richard McNally, John Kihlstrom and Harald Merkelbach (and their respective teams) who have quite a different interpretation of the research data. These researchers (and at this point I feel it necessary to declare my hand and alert the reader that I have published data on this topic which supports this perspective [e.g., Devilly et al., in press]) argue that there is a large body of research to indicate that memory is fallible, that memory can be influenced and distorted, that confabulation in memory can easily occur, and that those scoring highly on measures of dissociation are more likely to have generally worse memory and make more false recalls. They argue that this has been shown to be the case for both traumatic and non-traumatic memories with many types of people studied or treated by psychologists (e.g., Candel, Merkelbach, & Kuijpers, 2003; Clancy, Schacter, McNally, & Pitman, 2000). The argument here is that distortion of memory can occur at any of the three major stages of memory: at the time of encoding, during the period of storage, and when retrieving the information. Furthermore, inaccurate memories can be believed by the individual and described convincingly in as much detail as accurate memories. Indeed, these authors argue that there is evidence that false memories are more stable than true memories (particularly related to child memories), as true memories are based on unstable narratives while false memories are based upon relatively stable ideas.

Researchers who hold this perspective argue that there are many more likely interpretations of sudden and spontaneous claims of abuse. They argue that one possibility is that real abuse can be forgotten (as opposed to repressed) due to normal memory degradation over time. Although politically unpopular, they argue that a child may not interpret inappropriate sexualised behaviour as 'traumatic' at the time and hence the memory is not given any special weighting as a child. However, being reminded or brought to believe that these events occurred as an adult can be very distressing or traumatising. In essence, it is argued that one possibility is that they forget to remember the abuse because it held no special meaning for them at the time. Another possibility is that the person always remembered these events, but had not been given license to disclose them to another person, and that while they may not have thought about these events for many years, the memories were not repressed and inaccessible but rather suppressed and available. And, of course, another possibility is that there was no history of abuse and that the therapist has created a 'false memory' in someone looking for a reason for why they feel so distressed (frequently referred to as the 'effort-after-meaning' hypothesis).


False Memory Syndrome

At this point, I think it is necessary to also look at the term 'false memory'. Although this term has been around as a phrase for a long time and no one individual can really claim to have invented it, the term 'False Memory Syndrome' was introduced and defined by John Kihlstrom in the early 1990's around the time of the formation of the False Memory Syndrome Foundation. This is where the politics surrounding this whole issue becomes rather muddy. In possibly the most high profile case of 'recovered memories', the False Memory Syndrome Foundation was created in 1992 by Pamela Freyd after her daughter 'recovered' memories of her father (Peter) sexually abusing her as a child. This accusation occurred following a visit to a psychotherapist who had asked the daughter whether she had been sexually abused. Her mother, a Doctoral graduate in education, and her father, a professor of mathematics, deny any sexual abuse of their daughter (an academic psychologist) and have openly blamed the therapist with whom their daughter had consulted. Their daughter subsequently began researching recovered memories and, although there appears to have been no contact between the warring family for many years, the conflict has continued through other mediums in what one American newspaper writer termed 'America's most high functioning, dysfunctional family'. This history is on the public record and has been argued by both parties from both perspectives. I also mention this history not to side with one party or the other (as I hope is apparent from my summary of the history) but to explain the beginning of the False Memory Syndrome Foundation and to give more context for the intensity of the debate.

As should have become apparent, researchers from both sides see the possibility of people verbalising an as yet undisclosed memory of abuse, or remembering an episode of abuse otherwise not overtly recalled. However, the crux of the debate comes down to whether one sees it possible that a traumatic memory of abuse can be filed away (repressed) in such a way that the memory is inaccessible to the individual and that this memory can later be reliably recalled intact. Those who see this as possible and likely tend to advocate such treatment strategies as hypnosis and guided imagery. Those who do not see this as possible or likely tend to advocate therapist training in careful assessment methodologies to minimise the likelihood of false recalls, and the use of more mainstream cognitive behavioural strategies to address anxiety, depression and other manifestations of generalised distress. The latter argue that this can avoid the unnecessary heartache to all involved through false accusations, whilst the former argue that the problems will never disappear unless the roots of the condition (i.e., repressed memories of abuse) are psychologically excised. These people argue that to achieve this end one must create 'a proper environment' to allow the expression of these hitherto undisclosed memories - a phrase that obviously means different things to different people.

As I see it, the main reason for continued research in this field (irrespective of the heat of the topic) is to strike the balance between reducing the incidence of false positive recollections of abuse (i.e., people recalling abuse when in fact it did not occur) and hence creating more innocent victims, whilst at the same time reducing the incidence of false negative beliefs of abuse (i.e., a real victim not being believed by society) and hence disenfranchising a victim. Our best ally in this endeavour is not emotion but rather science - it is specific, falsifiable and replicable. The data is becoming really quite convincing these days. I don't believe therapeutic validation for the objectivity and accuracy of any claim (for the accuser or the accused) is wise without collateral support, yet I don't believe the personal answer to this balance and scientific debate will ultimately depend upon a court ruling.


The case of Jane Doe

An example of the depth of emotion stirred by the recovered memories debate is the case of Jane Doe. In 2002, Elizabeth Loftus and Melvin Guyer wrote a now famous (a few have termed it infamous) piece of investigative journalism on the case of Jane Doe in the Skeptical Inquirer. In 1997, David Corwin and Erna Olafson had written what they believed was a case study proving the veracity of the recovery of traumatic memories. In this case study it is claimed that Jane Doe had been assessed at the age of six years old by David Corwin (a psychiatrist), after her parents went through a protracted and vicious divorce - one during which her father and step-mother claimed that her biological mother had sexually and physically abused Jane. Having interviewed the child, Corwin accepted this claim and discussed the case at conferences over the next eleven years. Eventually he re-contacted Jane Doe who agreed to have their meeting videotaped. During this meeting, Jane claimed to not remember the sexual abuse and then came to spontaneously 'recover' these memories when asked about them by Corwin, and so was set the 'proof' of a reliable recovered memory. However, Loftus and Guyer (2002) published a long investigation into this particular case and the best way to describe their findings is to provide the name of the article: 'Who abused Jane Doe? The hazards of the single case history'. Both Loftus and Guyer subsequently had to (legally) defend themselves at their respective University ethics committees after complaints from those who disliked their outcomes and questioned their right to follow up other people's case studies and to act as investigative journalists. After horrendous stress, prolonged investigations and expensive defences, both were eventually exonerated of any wrongdoing.

However, the case did not stop there. More recently, Jane Doe somehow came to learn of the debate surrounding her case in the scientific literature and subsequently tried to sue Loftus and Guyer on a host of charges (most of which failed an appeal to be heard by a court). However, some charges related to invasion of privacy made it through this appeal, but were then appealed to the Supreme Court of California. Subsequently, the focus of the suing has changed to 'misrepresentation'. It appears that the foster mother (who looked after Jane when her father had a heart attack - her step-mother having divorced her father many years before - and with whom Loftus had spoken during her investigation) claims that Loftus misrepresented herself as Corwin's supervisor, a claim Loftus strenuously denies. Newspapers in the USA have taken a particular interest in this case as it has direct relevance to journalistic freedom to investigate claims. Newspapers have referred to the foster mother's claims that Loftus misrepresented herself as typical 'source remorse' (where a person who is interviewed comes to regret his or her statements and claims not to have said them or claims that they were obtained under false pretences, etc). So, in summary, Loftus and Guyer are again defending themselves from legal attack five years after publishing an article. The irony of this situation is that in order to file the suit Jane Doe had to identify herself - releasing to the public her real name and occupation, one easily found on the web with a simple search.

As of the 27th February 2007, the court has ruled that Jane Doe has not proven a prima facie case against Loftus and Guyer on three of the four charges brought against them (i.e., that they had no right to access previous court documents during their research, that Loftus breached confidentiality by using Jane Doe's real initials during a deposition, and that she breached confidentiality by mentioning Jane Doe's rank in the military during a conference talk). It is strange that Loftus and Guyer can be sued for these confidentiality issues when Corwin had shown videotapes of his interviews with Jane Doe (aged 6 and 17 years old) at a number of conferences, and during these tapes had used Jane's real first name and mentioned the city where she had spent some of her childhood (which enabled Loftus and Guyer to identify her in the first place). Either way, the failure of these charges now leaves just one charge to answer and Loftus and Doe's foster mother to argue who is telling the truth regarding how Loftus represented herself during her investigation. All appeal court costs (including Loftus') must be paid by Jane Doe. Whoever thinks the 'memory wars' are over needs to think again. It appears to me that clinical research subjects have themselves become the latest weapon, and collateral damage, in this whole torrid affair.



Candel, I., Merkelbach, H., & Kuijpers, M. (2003). Dissociative experiences are related to commissions in emotional memory. Behaviour Research and Therapy, 41, 719-725.

Cheit, R.E. (2007). The recovered memory project. Accessed 12th February:

Clancy, S.A., Schacter, D., McNally, R.J., & Pitman, R.K. (2000). False recognition in women reporting recovered memories of sexual abuse. Psychological Science, 11, 26-31.

DePrince, A.P., & Freyd, J.J. (2004). Forgetting trauma stimuli. Psychological Science, 15, 488-492.

Devilly, G.J., Ciorciari, J., Piesse, A., Sherwell, S., & Zammit, S., Cook, F., & Turton, C. (in press). Dissociative tendencies and memory performance on directed forgetting tasks. Psychological Science.

Loftus, E.F., and Guyer, M.J. (2002). Who abused Jane Doe? The Hazards of the Single Case History. Part I, May / June; Part II, July / August. Available at: