False-memory partisans sometimes grant the existence of recovered-memory cases involving a single instance of abuse, which they might then explain away as “normal forgetting” (although, of course, there is nothing “normal” about forgetting abuse). But there is a seemingly unshakable belief among those promoting “false memory syndrome” that repeated abuse would never be banished from memory. A documented case from Royal Commission into Institutional Responses to Child Sexual Abuse in Australia challenges this belief. Philippe Vincent Trutmann, who was sentenced to 6 1/2 years in prison in 2005, “admitted to sexually abusing [Luke Benson] 30 to 40 times over a two-year period.” But Mr. Benson, who remembers Trutmann as a “father figure,” has no recollection of the abuse, as indicated in this story.
People who identified themselves as “skeptics” of recovered memory used to ask “where are the corroborated cases?” This website originated after Ofra Bikel made the revealing admission that she could not find a single corroborated case after months of allegedly searching. We quickly found a handful of corroborated cases and this site was eventually born. Now there are more than 100 corroborated cases in the archive. And here is a media account of another case, this one from Florida, where a woman with recovered memories of abuse corroborated them by confronting the perpetrator and obtaining a confession. The man has since been arrested.
The Washington Post published a powerful essay by Danielle Bostick, who recently came to remember that she was sexually assaulted by her swimming coach, Christopher Huott, beginning when she was 7-years-old and Huott moved into her house. Bostick writes of hearing about the Rick Curl case in 2013, a case involving a swimming coach from the D.C. area who was charged and later convicted of sexually abusing a girl he had coached in 1986. Hearing news of Curl’s arrest, Bostick says: “I felt unsettled, but wasn’t sure why.” She did not identify herself at the time as a victim of her own coach.Within a year of hearing about the Curl case, Bostick approached the police with what she described as “little more than memory fragments and a gut feeling that I had been abused” by her own swimming coach, Christopher Huott.
The police arranged for a monitored telephone call to Houtt. As she described it, “for nearly two hours, [Houtt] confessed to abuse more horrifying than I had imagined or feared.” Huott was later charged with abusing Bostick; he eventually pleaded guilty to one felony count of child abuse and was sentenced to 10 years. Bostick’s case involves repeated sexual abuse that she had forgotten entirely and that was more than corroborated by the perpetrator. This case cannot be written off as “normal forgetting.” By all appearances, it is a corroborated case of recovered memory of severe childhood sexual abuse that occurred over a period of years.
An Australian newspaper reports that a 65-year-old man, who was originally convicted of sex abuse of two girls in 2008, had been convicted again in a retrial in County Court. The case apparently began with the report of a recovered memory of abuse by PL, the younger of two sisters. She reported the man to police in 1998. The man’s defense “was concentrated almost solely on the younger sister.” But PL “had not received any counseling before going to the police.” Moreover, her sister corroborated the charges. The jury found the man guilty for a second time, after his original conviction was overturned. The second conviction was just upheld on appeal. In short, this is apparently another corroborated case of recovered memory–from long after the era of discredited cases
Patihis, Ho, Tingen, Lilienfeld, and Loftus recently published a research article in Psychological Science related to the “Memory Wars.” The article carries the provocative title: Are the “Memory Wars” Over? A Scientist-Practitioner Gap in Beliefs About Repressed Memory.
The article is so flawed that one scarcely knows where to begin. It is a sure sign that something is seriously wrong when an article contains a significant misrepresentation in the second sentence. So it is with Patihis et. al., who summarize Professor Jennifer Freyd’s work as standing for the proposition that “memories of traumatic events can be repressed…and yet recovered accurately in therapy.” The authors cite, without a page number or quotation, a single publication of Freyd’s from 1994 that makes no such claim. Instead, Freyd makes the uncontroversial claim that psychotherapy can be useful for those who have experienced childhood trauma. Freyd also cautions, on page 320: “This aspect of psychotherapy and memory recovery also has the potential to lead to distortions in the interpretation of sensory, affective, and behavioral memories.”
One wonders why the authors did not portray the nuance in Freyd’s position. One also wonders why they ignored the substantial body of Freyd’s work in the years since 1994, including her highly-regarded Harvard Press book, Betrayal Trauma: The Logic of Forgetting Childhood Abuse. Freyd’s work is notable in part for highlighting two independent features of memory: continuity and accuracy. Freyd has always acknowledged that memory, both continuous and non-continuous, can be inaccurate. See her useful 2004 presentation at the American Association for the Advancement of Science on Misleading and Confusing Media Portrayals of Memory Research. It applies directly to Patihis et. al. and the attendant media coverage. Read more…
In an article about memory in the current New York Review of Books, Oliver Sacks displays a surprising myopia for someone who is generally sensitive to complexity and appreciative of case-based evidence. Dr. Sacks repeats the same fallacies about recovered memory that advocates for the False Memory Syndrome Foundation have long promoted. Sacks, who refers to “so-called” recovered memories, seems to think that because some recovered memories are false, none are true. The archive of over 100 corroborated cases of recovered memory at this site was created to counter that misconception.
Dr. Sacks also describes some of the well-known research that demonstrates that eyewitness testimony can be inaccurate. No doubt that is true. But no reasonable person takes that evidence to mean that eyewitness testimony can never be true! Nor would any reasonable person argue that eyewitness testimony should not be admitted in court unless it is corroborated by other sources. But that is precisely the position that false-memory partisans take about recovered memories. Dr. Sacks apparently has a similar view. One wonders why. (If Dr. Sacks disagrees with these extremists, we hope that he will clarify his position in the future.)
What is most disappointing about Sacks’ article is his credulous acceptance of the claims that there were “thousands” of cases of false memory in the 1990s. Remarkably, Dr. Sacks employs the phrase “almost epidemic” without substantiation of any sort. As it turns out, the evidence for that claim is beyond flimsy. It generally stems from surveys of those who claim that other people have experienced false memory. There are obvious reasons why the people answering such surveys might be dishonest. Evidence from the person supposedly afflicted with this “syndrome” is never included, violating the principles that created the Goldwater Rule. Would Sacks accept an estimate of the number of false convictions in criminal court that was based entirely on a survey of prisoners? Would he diagnose someone as having a neurological disorder (his field of expertise) without ever examining the patient? Assertions about “thousands” of cases of false memory suffer from both of these problems. For further elaboration, see this critique.
Of course memory is fallible. Who has ever claimed otherwise? Indeed, those claiming to be victims of false memory might be the ones who are misremembering the past, although curiously that possibility is never raised by false-memory partisans. (Their memories are apparently the ones that they consider infallible.) But one would hope that a doctor like Oliver Sacks would not extend the simple idea that memory is fallible to reach one-sided conclusions that ignore the case evidence and peer-reviewed studies about recovered memory. One would also hope that a doctor would never invoke the word “epidemic” without actual scientific evidence.
The Minnesota Court of Appeals ruled on Monday that Jim Keenan can proceed with his recovered-memory lawsuit against the Archdiocese of St. Paul & Minneapolis for personal injury and fraud. The court decided that Keenan should be able to present expert testimony that describes “memory repression and the characteristics that are present in an individual suffering from repressed memory.” (Doe 76C v. Archdiocese of St. Paul & Minneapolis; Court of Appeals of Minnesota, June 27, 2011). Overturning the trial court’s decision in the case, the appellate court also concluded that “genuine issues of material fact exist about when appellant was put on notice of a potential fraud claim.” Accordingly, Keenan’s claim that the archdiocese failed to disclose that Father Adamson had a history of sexual abuse will be allowed to go forward. One strong indication that the church knows that this claim is meritorious is that their spokesman is quoted as saying that the church “will continue to try and resolve the matter without the necessity of a trial.”
Pamela Freyd, Executive Director the False Memory Syndrome Foundation, said recently that the FMSF may soon quietly disappear. They apparently think that their work is done. But the unanimous decision of this three-judge panel once again demonstrates that, fortunately, recovered memory deniers have not won the so-called memory wars. Instead, common sense still prevails at the Minnesota Court of Appeals.

Francis DeLuca admitted that he sexually abused John Vai (and others)
Yesterday, a jury in Dover, Delaware found that St. Elizabeth Roman Catholic parish was grossly negligent in its failure to properly supervise then-priest Francis DeLuca and is responsible for $3 million of $30 million in damages awarded to John M. Vai, who repeatedly was molested as a teenager in the 1960s.
According to the Wilmington News Journal, the jury found that Vai only became aware of the sexual abuse he suffered as a child in 2007 after reading an article about a different priest sex abuse case brought against DeLuca. As an earlier story about Mr. Vai’s testimony explains, “Vai testified that he repressed the memories of abuse until he read about a lawsuit filed by Robert Quill in 2007 charging that DeLuca molested him. Quill was younger than Vai but lived in his neighborhood and walked to school with him. Vai said the story caused him to explode with emotions, the memories came flooding back and he was filled with guilt and shame that he had not spoken up in 1966.”
Since the recovered memory of sexual abuse in this case is corroborated by DeLuca’s confession, there is no question that his memory was true. So, will the False Memory Syndrome Foundation express condemnation of the perpetrator and those who covered up for him? Or will they side with the perpetrator because they are unwilling to recognize even the most corroborated cases of recovered memory? Or will this be another one of the multitude of cases on this site that the FMSF never acknowledges?
Calvin Huss, of Port Deposit, Delaware, pleaded guilty yesterday to sexually abusing a 13-year-old girl during a seven-month period in 1993. His confession, according to a news report, “came a month after the victim, now in her early 30s, contacted state police following a repressed memory breakthrough during psychological therapy.”
Huss also confessed to sexually abusing a 15-year-old girl and a 17-year-old girl between 2008 and 2010. His guilty plea was part of a plea deal in which prosecutors agreed to drop related charges.
This case is important not only for adding to the number of corroborated cases of recovered memory of childhood sexual abuse, it is also important because the memory arose in therapy. Recent research, ignored by FMSF partisans, has concluded that memories recovered outside of therapy have a corroboration rate equal to continuous memories of abuse. But Geraerts et. al. (2007) reported that none of their subjects who reported recovering memories of abuse during therapy were able to obtain corroboration. This case challenges the generalizability of that conclusion.
A recovered memory by a woman in Nevada just led to the arrest of Fermin Ivan Perez (pictured at left) for kidnapping and sexual assault in 1998. According to one news report, the woman’s “recollection 12 years later was so vivid it led police to both a location and a suspect.” The suspect was subsequently linked by DNA evidence to the crime, according to the Las Vegas Review-Journal. What will those who deny the existence of recovered memory possibly argue—that she remembered all along but wanted, for some reason that would not benefit her, to have the case remain unsolved for years?
This is not the first cold case to be solved by recovered memory. Travis Vining’s recovered memory solved two murder cases from 1987. Here is the beginning of a three-part article from the Orlando Sentinel about Vining’s recollection and the tape-recorded confession and subsequent guilty plea that it produced in 2007. What will those who deny the existence of recovered memory possibly argue—that he also remembered all along but also wanted, for some reason that would not benefit him, to have these cases remain unsolved for years?