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Keyword: ‘contest’

False Dichotomies and Other Errors in Patihis et. al.

December 31st, 2013 Comments off

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…

“False, Preposterous and Unjust”

May 31st, 2012 Comments off

That is how Cardinal Timothy M. Dolan responded to questions about whether his diocese provided pedophile priests with $20,000 pay-offs to leave the church. The language of denial is often filled with righteous indignation. The only problem is that the Cardinal was lying. As reported in today’s New York Times,  a spokesman for the archdiocese confirmed  that payments of as much as $20,000 were made to “a handful” of accused priests “as a motivation” not to contest being defrocked.

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The Misrepresentation of the Case of Billy Banks

October 31st, 2010 Comments off

The False Memory Syndrome Foundation claims to condemn the sexual abuse of children. In their words, “Child sexual abuse is a reprehensible crime….Every effort should be made to help victims of sexual abuse and to create a social climate in which such mistreatment does not continue to take place.” So why did they sympathize with Billy Banks, a serial child molester?

This is the first in a series of occasional posts that will highlight and document cases in which the FMSF has taken the side of someone charged with child sexual abuse without apparent regard for the evidence of guilt.

The Case against Billy Banks

Billy Banks was convicted in 2005 on 10 counts of sexual battery on a child under 12 years of age. (Three counts were overturned on appeal—two on double jeopardy, and one was outside the statute.) The charges included acts of rape, forced oral sex, and fondling of his daughter and his adoptive niece from 1965 to 1970. Banks was also facing two charges of lewd, lascivious or indecent acts on a child under 16 for sexually abusing his two granddaughters 20 years later, in 1990-1. After being convicted on the first counts, Banks pled no contest to one of these later counts. He was sentenced to life on the sexual battery charges and three and a half years for the charge to which he pled no contest.

Read more…

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Harrison Pope’s Phony Repression Challenge

September 27th, 2010 Comments off

Dr. Harrison Pope got a lot of publicity in 2007 for his “repression challenge,” which offered $1,000 to anyone who could find an example of repressed memory before 1800. Pope et al. later published a paper that argued that the failure of anyone to find an example proved that repressed memory was a social construction.

There is one major problem: someone did win! The winning submission was entered after Dr. Pope and his co-authors published the article that is still highlighted on his home page. The article says that the lack of any examples before 1800 proves their argument; but the article also allowed that an example that fit their narrow criteria would disprove their claim. Applying a version of logic that rivals “heads I win, tails you lose,” Dr. Pope has since claimed that he is still right, even though he lost.

He has also gone to notable lengths to conceal the winner, who was acknowledged only briefly on his home page. But that heading (pictured below) was quickly removed, and for the last two-plus years the site has highlighted only the outdated article. Remarkably, Dr. Pope did not withdraw the article even though its conclusions were disproved after publication.

Click here to see the site as of 9/27/10, with announcement of winner removed. [Summer 2013 note: the site has apparently been removed entirely.]

That isn’t the only problem with the “challenge.” The definitions created by Dr. Pope were so narrow that they rejected a host of examples from hundreds, even thousands, of years ago. For example, Pliny the Elder said in the year 77AD that memory is “affected by disease, by injuries, and even by fright; being sometimes partially lost, and at other times entirely so” (Pliny the Elder, The natural history of Pliny (J. Bostock & H. T. Riley, Trans.), London: George Bell & Sons, p. 165 (1893)). Dr. Pope rejected this evidence because, in his words, it did not specify that fear, per se, could cause memory to be entirely lost. See also Ben-Ezra, “Dissociative symptoms after plague in the 15th century,” British Journal of Psychiatry, 86:543 (2005). For a detailed critique of the contest see Goldsmith, Cheit and Wood, “Evidence of Dissociative Amnesia in Science and Literature: Culture-Bound Approaches to Trauma in Pope et al. (2007),” Trauma and Dissociation, 10:237-253 (2009).

FAQ

June 3rd, 2010 Comments off

What are the strongest cases in the Archive? This depends on which form of evidence you find most convincing. The cases adjudicated in criminal court were subject to the highest standard of proof, so these might be considered the most convincing cases. Perhaps most convincing are those where the defendant did not contest guilt, since those cases pose no factual question as to whether the abuse occurred. Then again, claims of innocence notwithstanding, there are cases in the archive that involve eyewitnesses, medical evidence, and physical evidence. There is even a case that an adjudicator found to meet Biblical standards of proof: two witnesses. Some people find clinical cases more convincing than court cases, since they do not evolve through the adversary system. Accordingly, the Archive contains a range of cases. Different people will find different kinds of cases to be the most persuasive.

Why do some cases have documentation, while others have minimal information? The Archive was established with the minimum standard that “cases” had to be identified with sufficient specificity that other researchers could find the case as published or have sufficient leads that researching the case would be possible. Some cases in the archive exceed that standard because additional information has been made available, along with consent to use it on the Web. Public information supplements other cases, where possible. It should be noted that this minimum standard has almost never been applied to the countless “cases” reported as false-memory. Many claims about the prevalence of that phenomenon and the merits of various cases remain unscrutinized by scientific processes such as replication and verification. The cases in this Archive are all open to scrutiny. The clinical cases are cited by publication, and all remaining cases are identified with sufficient specificity to conduct additional research.

Have any cases been removed from the Archive? Yes. Three cases have been removed over time. Most recently, a case from the Legal section, Commonwealth v. Slutzker, was removed and placed on hold pending additional legal proceedings.

Two other cases were removed at a previous update, based on information provided by people who looked into those cases further. Both had been misreported in the press. First, the Owen Dulmage case from Canada was removed. While a major press report clearly indicated otherwise, later coverage indicates that the delay in coming forward was psychological, not memory-related. While remembering his abduction all along, Mr. Helferty “said that 38 years later, one of the things that disturbs him most is his inability to remember the details of his final four nights as a hostage.” Roik, “‘Boy snatcher’ still a risk; Crown seeks 4 years for ‘disturbed, dangerous’ Dulmage,” Ottowa Sun (March 3, 1999): p. 7. The second case removed from the Archive is the Shacklett case from Mt. Clemens, Michigan. It was also removed for the same reason as the Dulmage case. As it turns out, most of the coverage of this case misreported the memory issue, deeming it “a repressed memory case.” It now appears that the defense characterized the memory as “repressed,” an increasingly common technique of impugning those with continuous memory by falsely claiming that their memory was recovered. It should be noted that both of these cases are clearly corroborated cases of sexual abuse. But neither involved recovered memory.

Isn’t recovered memory something that faded in the 1990s? No. False-memory partisans were successful in capturing the media in the 1990s and in a limited number of states law changes (by court and legislatures) made it harder for adult victims of child sexual abuse to bring any kind of claim. But the phenomenon, while harder to observe and therefore much less likely to be reported, certainly continues. The first murder conviction in England based on recovered memory testimony occurred in 2002 (based on a woman’s long-buried memories of her mother’s death, recovered “during counseling sessions” in 2000). This case is in the Archive. Others currently pending inclusion include Gregory Ford’s recovered memory (in 2002) of sexual abuse by Father Shanley, then of the Boston Diocese. Similarly, memories recovered in 2002 formed the basis for an ex-resident’s lawsuit against Boys Town filed in February 2003. Similarly, a pending lawsuit against the old, Catholic-based Peter Pan program in Florida is based on a memory recovered in 2001. Future updates will add these cases (and others) to the Archive as events warrant.

What about “false memory syndrome”? There is no such thing as “false memory syndrome.” This “syndrome” has not been recognized in the DSM. Rather, it is “a non-psychological term originated by a private foundation whose stated purpose is to support accused parents.” A group of researchers with “a common concern for the responsibility of psychology as a science” signed a letter to the editor in the APS Observer in 1993 urging, “for the sake of intellectual honesty, let’s leave the term ‘false memory syndrome’ to the popular press.” Read this important, but often overlooked letter (180K PDF).

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Other Corroborated Cases (33)

June 3rd, 2010 Comments off

The cases in this file don’t fit comfortably into either of the other categories. Many of the cases are “legal” in the sense that they involve legal claims—but the ones in this file were not allowed to go forward, most often on grounds involving the statute of limitations. This archive preserves the corroborative facts that the plaintiff tried to introduce in those cases. A few others are pending but clearly have corroboration. Most of the remaining cases are cases reported solely in magazines or newspapers, often by journalists who spent a considerable amount of time investigating. For example, the case uncovered by Tad Shannon in the Eugene Register-Guard in 1998 is unquestionably a powerful case of recovered memory; so is the one self-reported by Jill Christman (and consciously avoided by Ofra Bikel in her PBS “documentary” on recovered memory).

1. Jill Stimson’s memories of childhood sexual abuse by her father. “In times of intimacy with her husband [beginning in the late 1960s], Stimson began having disturbing flashbacks”—both vague and horrifying. For years, she struggled with low self-esteem and other problems, but she never identified the source of the flashbacks. “It wasn’t until 1982 that Stimson learned what happened.” Her mother, moved by the knowledge that her ex-husband was occasionally babysitting Stimson’s daughter, told her, in hopes of protecting the granddaughter, that “when you were a little girl your father molested you.” The mother had seen physical evidence at the time, had confronted the father, and had even consulted a lawyer. (Tad Shannon, “Memory and the mind: recovered memories lead Eugene woman to a painful truth,” Eugene Register-Guard (July 11, 1998: A1).)

2. Jill Christman’s recovered memories of childhood sexual abuse. Ms. Christman’s case is noteworthy for at least two reasons: first, she obtained verification from a childhood friend who witnessed the abuse; second, she told the entire story to Ofra Bikel of PBS, who later claimed (erroneously) that she could “could not find” any corroborated cases of recovered memory. (See Christman, J. (1998). “Quieting Doubt: The gift of corroboration,” Moving Forward Online, 4(1).)

3. Marilyn Van Derbur’s recovered memories of child sexual abuse (revealed publicly in Denver, Colorado, May 1991). Her memories were corroborated by her sister, Gwen Mitchell, who had continuous memory of similar abuse and who long thought she “was the only one” sexually abused in the family. (Fawn Germer, “Ex-Beauty Queen’s Sister Acknowledges Father Molested Her, Too,” Rocky Mountain News, May 11, 1991:6.)

4. Cynthia Yerrick’s recovered memories (in 1991) of verbal, physical, and sexual abuse by the Rev. Robert E. Kelley (in the mid-1960s). Ms. Yerrick recovered the memories in therapy. “Asked by her therapist to draw a picture of what made her so angry, the troubled young mother of two felt a sudden rush of emotion. She sketched the Catholic Church she attended as a 4-year old in a small Massachusetts town.” (Jason Wolfe, “Woman Relies on Repressed Memory in Alleging Priest Abuse,” Maine Sunday Telegram (October 26, 1997: 1B).) Soon thereafter she began recalling horrifying memories of abuse. “With the memories bubbling to the surface, Yerrick and her husband, who salvaged their marriage, decided to find out about Kelley. They learned that three years earlier, in 1990, he had pleaded guilty to molesting a 10-year-old girl and had been sentenced to five to seven years in state prison.” (Id.) Ms. Yerrick was awarded $527,734 by Judge Daniel Toomey in a lawsuit against Kelley. (Richard Nangle & Gary Murray, “Ruling against priest,” Telegram & Gazette (Worcester, Ma.) (October 18, 1997: A1).) In Yerrick’s suit against the church, which is still pending, Judge Fremont-Smith recently found the diocese in “serious and culpable non-compliance” with the rule of civil procedure for, among other things, trying to conceal corroborating evidence. “The judge found that the diocese withheld a 1963 pastor’s report on Kelley in which his pastor answered ‘yes’ to the question, ‘Has he conducted himself with persons of the other sex in such a way as to cause scandal, criticism or suspicion.’” (Dianne Williamson, “Court raps diocese’s knuckles,” Telegram & Gazette (Worcester, Ma.) (July 21, 1998: B1).)

5. Linda Lee’s recollections of child sexual abuse (Florida, 1992). “Linda Lee can see flashes of her childhood. Horrendous images: a relative forcing oral sex on her when she was 3 and 4, the same man raping her when she was a teen, his big hands gripping her throat to hold her still….[Lee] says she didn’t remember one single detail of a childhood filled with sexual abuse until she was an adult. Her mother finally confirmed it this year and her abuser, when confronted, didn’t deny it.” “In the case of Linda Lee, her mom recently admitted that she knew what was going on, but was too emotionally battered herself to protect her daughter. A childhood friend told Lee last year that she once saw Lee being attacked, but was afraid to tell.” (Tracie Cone, “Memories of Sex Abuse,” Miami Herald, June 7, 1992: 1J.)

6. The initial complaint against Norman Ackison for rape and child sexual abuse. (Separate complaints were ultimately the basis for criminal charges, but those complaints certainly corroborate the recovered memory.) “A number of adults in the Shasta Drive neighborhood recalled being victimized by Ackison when they were young, Patten said. However, no charges could be brought in those cases because…the statute of limitations had expired.” Ackison was eventually charged for offenses involving “three girls between 5 and 6 [that] occurred between September 1989 and February 1991. Ackison surrendered after being featured on America’s Most Wanted.” “The investigation was triggered when one of the victims became upset after watching an episode of In the Heat of the Night featuring a child abuse case.” (Jim Woods, “TV Show May Have Scared Accused Child Abuser Into Giving Up,” Columbus Dispatch, April 16, 1992: 3D.)

7. John BBB Doe’s and John MMM Doe’s recovered memories of childhood sexual abuse by Rev. William J. Effinger. These plaintiffs were joined in a civil suit by five others who had always remembered abuse by Rev. Effinger but who did not understand its significance until adulthood. The repressed memory claim for BBB and MMM “was included in their briefs in opposition to the motions to dismiss.” )Doe. V. Archdiocese of Milwaukee (1997), 211 Wis 2d. 312; 565 N.W. 2d 94; footnote 1.) The Wisconsin Supreme Court prohibited all seven suits from proceeding, arguing that only the legislature can extend the statute of limitations in such cases.
The corroboration for the two men with recovered memory extends far beyond the others in this lawsuit. Seven other men and two women who were abused by Rev. Effinger in Wisconsin reached out-of-court settlements with the Archdioscese of Milwaukee. (“Church Settles with 9 for Abuse by Priest,” Chicago Tribune (December 1, 1993: p.3). Those claims spanned 20 years—“from the priest’s first parish assignment to his last.” (Id.) In 1993, Father Effinger entered a no-contest plea in Sheboygan County to second-degree sexual assault against a 14-year-old boy. He was sentenced to 10 years and died in prison.

8. Janet Ostrowski’s memories of child sexual abuse by Rev. John Mott, pastor of St. Catherine of Sienna Roman Catholic Church in Franklin Square. Ms. Ostrowski was prohibited from pursuing the claim because of the statute of limitations, but “four more women subsequently contacted the Roman Catholic Diocese of Rockville Center to say that they had been sexually abused by Mott when they were teenagers.” (Stuart Vincent, “Dismissal of Abuse Suit Appealed,” Newsday (May 11, 1995: A31).)

9. Angela Mitchell’s flashbacks of being sexually abused 27 years earlier by Monsignor Arthur Sego at the St. Patrick Catholic School. “Mitchell repressed her memories of the incidents until April 1994, when she began helping an abused boy while working as a teacher’s aide at the Kokomo YMCA.” (“Kokomo Woman Says Monsignor Molested Her,” Gary Post-Tribune (March 5, 1995: B12).) Mitchell told her older sister at the time of the abuse. Her sister told her mother, who contacted the diocese in Lafayette, “but a bishop there allegedly told her not to tell anyone, saying that church officials would handle the situation.” (Id.) (The Monsignor was sent to the St. Joseph Mother House for two and a half weeks to reflect on what had occurred. He also received psychiatric therapy for two and a half months. He was then assigned to a different parish.)
The Bishop confirmed the basic facts in a 1967 letter that ended, “I would suggest that you might destroy this letter after you read it. In this way, we will protect both [A.M.] and Monsignor.” (A.M. v. Roman Catholic Church, 669 N.E.2d 1034 (Indiana Court of Appeals, 1996.) The mother “followed the Bishop’s instructions and never again spoke to A.M. about the molestations. The older sister also kept the secret.” (Id.) Remarkably, the Indiana Court of Appeals did not allow Mitchell to proceed with her highly-corroborated claim because the perpetrator was not a family member, and she did not bring the suit before turning 18—something that would have been impossible, since her first recollections were at age 34.

10. Stephen McCaffrey’s adult recollections of sexual abuse by Rev. Robert J. Vonnahmen at the Belleville diocese camp. “Neither [another abuse survivor] nor McCaffrey used hypnosis, or was in therapy at the time of the flashbacks.” The suit was still pending at the time of this article, which also states that “Rev. Vonnahmen is one of eight priests who have been removed from their duties in the Belleville diocese.” (Virginia Baldwin Hick, “False ‘Memories’ a Growing Issue in Abuse Cases,” St. Louis Post Dispatch, March 3, 1994: 5B.)

11. Former altar boy in Baltimore who requested anonymity but whose adult recollection of abuse resulted in the removal of four priests. The victim told the Washington Post that the “molestations began when he was 11 or 12 and continued until he was about 17. He began having marital problems several years ago and sought therapy. On January 19 [1995], he met for nearly two hours with Monsignor William Lori. The next day, Lori separately interviewed the four priests and each admitted to the victim’s allegations.” (Clari.news.crime.sex; article 865, February 6, 1995; see also “4 Priests Removed After Admitting They Molested an Altar Boy,” New York Times, February 7, 1995: A14.)

12. Kevin MacKenzie, former altar boy in Pennsylvania, who “did not remember the abuse until certain events triggered his ‘repressed memory’ in 1993.” A New Jersey appeals court dismissed his case under the statute of limitations. (“N.J. Court Dismisses Lawsuit Against Priest,” Philadelphia Inquirer, July 25, 1995: N1.) While this case was pending, Kohler was apprehended for his involvement “in taking ‘suggestive photographs’” of young boys with ex-priest William O’Connell. (“Priest Will Face Obscenity Charge,” Bergen County Record, July 13, 1994: A6.) “Thousands of photographs of young boys, some of them naked, were found in the home.”

13. Juror Crawford in Gerald Amirault’s infamous child molestation case. According to Jonathan Harris, “the day after he was convicted, an anonymous caller called his lawyer to tell him that a cousin of his spent time in prison many years ago for raping one of the jurors when she was about 14. Juror Crawford insisted that she did not remember the rape and must of [sic] repressed it.” Harris also states that Juror Crawford had indeed testified at a preliminary hearing and at a trial that resulted in conviction just about forty years and forty days before Gerard Amirault’s conviction. (WITCHHNT posting, May 2, 1995.)

14. Susan Lees’ recovered memories of horrendous physical and sexual abuse as a child (Birmingham, England; 1997). Ms. Lees was adopted at the age of five by a family who treated her as one of her own and who did not know about the abuse that she had already suffered. Her memories of abuse did not begin until she was 35. Lees was listening to a news report from Bosnia on her car radio and heard the screams of a young girl in Bosnia having shrapnel removed from her back without an anesthetic:

“The next thing I knew I had pulled over and was crying uncontrollably. When I got home I dashed into the attic to get my old doll out of the loft. I started to bathe and wash because I felt dirty. For weeks afterward I bathed and scrubbed my legs because they itched. It got to the stage where they were raw.” (Lucy Johnston, “Memories of Child Abuse Spark Lawsuit,” The Observer (March 2, 1997): 3.)

Fearing that she was going insane, Lees contacted a GP, who referred her to a therapist. During the next six months more flashbacks came back. Then she set out to find her social service records. “Documentary evidence from more than 30 yeas ago confirms that Ms. Lees’ mother left her alone with an alcoholic father when she was nine months old, and that social workers sent her to live with a friend of her father who the NSPCC knew to have been involved in child abuse.” (Id.) The itching turned out to be an actual memory of being defleaed when she was admitted to the hospital at age four; according to medical records, she was anemic and had screaming fits. Ms. Lees also “has evidence that she was buggered and had her toes smashed with a hammer” before she was adopted. (Id.)

15. Terry Throneberry’s recovered memories (in 1990) of sexual abuse by Rodney Grantham at the Shults-Lewis Children’s Home between 1960 and 1969. Throneberry claims that Grantham impregnated her when she was 14 years old and gave her “pills containing quinine which caused vomiting, diarrhea and bleeding, and resulted in abortions.” These memories, recovered in therapy, were corroborated by Margie Cole, who had continuous memories of similar abuse by Grantham in 1962. (Matthew Tully & Frank Wiget, “Court: Woman’s Case Can Proceed,” Post-Tribune (Gary, Ind.) (March 19, 1997: A1).) The memories were also corroborated by Grantham, who “admitted to the allegations in court papers” but challenged the suits on statute of limitations grounds. (Michael Puente, “Lawsuit Pivots in Ruling on Repressed Memory,” Post-Tribune (Gary, Ind.) (September 11, 1995: A1).) The Indiana Court of Appeals allowed Throneberry’s action to proceed, agreeing that she “had no independent memory [before 1990] of Grantham sexually molesting her.” (Cole v. Shults-Lewis Child and Family Services, 677 N.E.2d 1069, 1074; 1997 Ind. App. LEXIS 177 (March 18, 1997).)

16. Lisa Shogren’s 1992 criminal complaint against Lee Roy Donnell for child sexual abuse. Ms. Shogren “testified at pretrial hearings that her memories of that [assault] and other incidents had been repressed until she entered therapy in recent years.” Donnell was convicted of sexual battery. (“Father Guilty in Assault,” Washington Port (September 10, 1992): B3.)

17. Adam Farthing’s successful claim for childhood sexual abuse before the Crimes Compensation Tribunal in Melbourne, Australia. Claim corroborated by two siblings. Formal hearing on February 2, 1998.

18. Mary Staggs recovered memories of sexual abuse by Father John Lenihan, her priest in early adolescence in Anaheim, California. Staggs went to police when she experienced flashbacks at age 26. The criminal statute had run out, but she was able to pursue a civil damage suit. In a deposition, Lenihan admitted to fondling Staggs in 1978. In 1991, the Diocese of Orange paid Mary Staggs an out-of-court settlement. (Jason Berry, “Fathers and Sins: An Uneasy Coalition of Activists and Clerics is Forcing the Catholic Church to Confront the Problem of Sexually Abusive Priests,” Los Angeles Times Magazine (June 13, 1993).)

19. Marguerite Hurt’s repressed memory of being raped by three U.S. Army soldiers the night before leaving Vietnam more than twenty years earlier. The case is corroborated by medical records indicating that she contracted gonorrhea. (Dave Moriz, “Vet Center Seeing Scars of Sexual Battlefields,” Columbia [South Carolina] State (October 20, 1995), p. A1.)

20. Dodds v. Johnson, a civil settlement in October 1998 in one of the first recovered memory cases in South Dakota. Sister verifies plaintiff’s recovered memories; mother was also going to testify in plaintiff’s favor. Defendant offered to settle after the jury was selected.

21. Lund v. Giesen (Scott County, Minnesota), Case No. 97-19193. Civil settlement immediately after Judge Rex. Stacey ruled (2/16/99) to allow recovered memory testimony. The perpetrator admitted to some of the acts in deposition.

22. Allen Levinson’s grown daughter’s recovered memories of childhood sexual abuse by her father. Corroborated by her father’s sexual-abuse charge and subsequent 15-month prison sentence for sexually assaulting a seven-year-old girl in Cook County. (Desiree Chan, “Jail-bound for fraud, man admits sex abuse,” Chicago Tribune (February 19, 1998), p. 1.)

23. The recovered memory of a Mount Lookout, Ohio man who, after entering therapy, recalled childhood molestations by former priest and admitted pedophile George Cooley. (Phillip Pina and Erin Gibson, “Lawsuit filed against archdiocese, convicted ex-priest,” Cincinnati Enquirer (Jul 16, 1999), p. D1.) The suit was settled right before the case was to go to trial in July 2000.

24. David Clohessy’s recovered memory of childhood sexual abuse between 1969 and 1972 by Rev. John Whitely in the Diocese of Jefferson City, Missouri. His suit was dismissed because of the statute of limitations, but Mr Clohessy’s claim was nonetheless corroborated when “Whitely was removed from active ministry in light of what a diocesan spokesman calls credible accusations against him.” (Frank Bruni, “Am I My Brother’s Keeper?” New York Times Magazine, May 12, 2002.)

25. Lee White’s recovered memory of sexual abuse in 1970 by Father James Silva in Newport, Rhode Island. Mr. White recovered the memory after going into therapy. He filed suit six months after the memory emerged. (See CNN Talkback Live (March 18, 2002) [Transcript #031800CN.V14].) The lawsuit settled several months later.

26-28. “Several cases” (counted, for this Web site, as 3 cases—it may well have been more) included in a settlement with the Roman Catholic Diocese in Tucson involved repressed memory. (See “Diocese settles over civil lawsuits that alleged molestation,” AP State & Local Wire, January 29, 2002.) The terms included public and personal apologies to victims and their families. Note: there was no “advantage” or “incentive” for these “few cases” to claim recovered memory. Given the current climate, it is arguable that if they wanted to be deceptive for gain, it would be more advantageous to claim continuous memory.

Additional details are provided in a later article. George Sanchez’s memory of being sexually abused at age 12 by the Rev. Julian Sanz during confession in the priest’s office in Tucson, Arizona was repressed until 1996. “Sanchez repressed the memory of what happened while inside Sacred Heart Church in Douglas, where he was a devout Catholic.” (Sheryl Kornman, “Paying the price of sexual misconduct by priests,” Tuscon Citizen, July 9, 2005.) Sanz pleaded guilty to two counts of child abuse in 2003 and is currently in prison. “Sanchez is of one of a number of victims with repressed memory whose claims of abuse were found to be credible by the diocese.”

29. Mike, a retired construction supervisor in Anchorage, Alaska, whose recovered memory of abuse at the hands of Rev. Francis Murphy in a Catholic Junior High School locker room was corroborated by a witness/participant at the time who never forgot. (Nicole Tsong, “Sins of the Father,” Anchorage Daily News (August 3, 2003), A9.)

30. An unidentified man’s recovered memory of being sexually abused by Robert L. Mueller in 1982 in the Boy Scouts. His subsequent report to the police resulted in Mueller’s arrest on child pornography charges. The criminal complaint says two other men who were Boy Scouts at the time also reported being sexually assaulted by Mueller. McCormick, “Former Scouts leader charged in child porn case,”Milwaukee Journal Sentinel, (December 3, 2004).

31. Ralph Cosimo’s “repressed memory of multiple instances of [sexual] abuse” by Rev. James F. Rapp of the Catholic Diocese of Salt Lake City in the early 1970s. Rapp was defrocked and is currently in prison for molesting a boy in Oklahoma. Ralph Cosimo’s memory is corroborated by his brother’s continuous memory and by an admission by Rapp. The church’s defense to civil litigation was based on the stature of limitations. The defense even argued that Rapp had acknowledged to Ralph in 1975 that he was a pedophile and that he was abusing his brother at the time. (An appeals court in Utah disallowed the lawsuit on statute of limitations grounds.) (See generally Romano, “Okla. Archbishop Failed to Oust Priest; Long Trail of Abuse Prompts Complaints,” Washington Post (May 21, 2002). See also Neff, “Court rules brothers waited too long to sue,” Salt Lake Tribune (November 27, 2004).)

32. Steve Cysewski’s recovered memories of abuse by Rev. Robert Marcantonio. In 1971, at the age of 11, Steve Cysewski was molested by his priest, Reverend Robert Marcantonio. Cysewski had approached his priest to help him with his bedwetting problems. Marcantonio continued the abuse over two years, after which Cysewski became homeless and suffered from alcoholism. Cysewski repressed his memories until he was 21 in 1981, around the time of his father’s death. He threatened to go court 20 years later, in 2001, but reached a settlement with the Archdiocese of Dubuque. He is one of Marcantonio’s over two dozen alleged victims, six of whom reached a settlement in 2002 with the Diocese of Providence. (See Nevans-Pederson, “Abuse victim sought help from priest,” Telegraph – Herald (October 11, 2006).)

33. Diane McKenzie’s recovered memories of abuse by priest Emilio Garcia. Diane McKenzie was abused and raped by Emilio Garcia, a Spanish priest, in the 1960s and came forward in 2000 in Pinellas County, Florida, when she was working as a junior sacristan at St. Patrick’s Catholic Church. McKenzie’s memories started to resurface only after 34 years had passed since the abuse, when her brother was getting married. McKenzie went to confront Garcia when she remembered the incidents, and he admitted to the crimes. As a result, the Diocese of Orlando removed him and sent him back to Spain. (See Day, “Their struggle put a face on clergy abuse,” priest,” St. Petersburg Times (February 5, 2007).)

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Legal Cases (53)

June 3rd, 2010 Comments off

All 53 of the cases in this file involve claims in legal proceedings. Some cases are criminal, some are civil, and a few are administrative or involve an estate. The criminal cases all resulted in either a guilty verdict or a guilty plea. The civil cases all resulted in either a civil judgment or a civil settlement. The cases included pre-trial discovery on the facts, and often full-blown adjudication. In short, the corroboration in these cases has been scrutinized and in many cases verified through a legal proceeding.

1. K.B.’s recovered memories of childhood sexual abuse by a neighbor and close family friend. K.B. v. Mathes (U.S. District Court, Eastern District of Washington). Filed in 1982 (Docket No. C-82-56), decided January 5, 1984 by Judge Justin L. Quackenbush. Judgment for the plaintiff; no appeal by defendant.
“K.B.’s testimony is confirmed to some extent by her sister Lisa’s testimony. Then we have what I call the age fourteen alcohol incident…the incident when K. arrived home in an intoxicated state. (Oral decision, filed January 11, 1984, p. 2.) “Then we have Mr. Mathes’ own testimony that the only statement he made to Mrs. B was that ‘I wish it hadn’t happened.’” (Id. at p. 4.) [Additional evidence of financial payments by Mr. Mathes as indicating “some scienter or guilty knowledge on the part of Mr. Mathes” on p. 5] Finally, “based on the evidence presented in this case….I find that K.B. completely repressed her recollections of the defendant’s wrongful conduct from the time of her high school years when she was obviously a minor until she began seeking counseling for her depression and anxiety in late 1979.” (Id. at p. 9.) “I further find that it was not until at least April of 1981 that Ms. B. was able to fully recall the acts of misconduct by the defendant.” (Id. at p. 10.)

2. Dulaney Collins’ memories of childhood sexual abuse by her father. The memories first surfaced while she was hospitalized in 1984. Ms. Collins filed a criminal complaint several years later, and her father, Landon Carter Smith was charged. He later pled guilty and was placed on lifetime parole and ordered by the court to have no further contact with his daughter. Commonwealth v. Smith (felony criminal case: Petersburg Virginia, 1990).

3. Meiers-Post v. Schafer (Michigan Court of Appeals, 1988). A civil suit by Jan Meiers-Post against her former high school teacher for sexual abuse from 1970 to 1974. “We hold that the period of limitation is tolled where the child victim of an illicit sexual relationship psychologically represses the memory of the events and where, after the memory is revived there is corroboration that the events actually occurred.” “In his deposition, defendant admitted to having sexual intercourse with plaintiff, at various times, from 1972 to 1974.” 427 N.W. 2d 606, 607.

4. State v. Wilson (Polk County, Iowa; August, 1990). Criminal conviction of Thomas Dean Wilson for incest and third-degree sexual abuse of his daughter. “The trauma was so great that she was unable to remember for eight years—and then only after months of therapy.” (Marie McCartan, “‘Daddy Hurts Me’…The Horror of Incest,” Des Moines Register, February 17, 1991: 1E). The corroborating evidence uncovered through discovery included ‘inappropriate advances’ made by the defendant toward another minor in his role as a church chaperon and a former teenage babysitter for the family who had repeated sexual relations with the defendant. There was additional corroboration from M’s childhood medical records. Twelve jurors found Tom Wilson guilty beyond a reasonable doubt. Id.

5. Nicolette v. Carey (Federal District Court, Western District of Michigan, 1990 judicial decision). Civil action by Suzanne Nicolette against her father, Joseph Carey, for childhood sexual abuse first remembered in adulthood. In denying the defendant’s motion to dismiss the case, Judge Benjamin F. Gibson noted that “plaintiff has submitted a letter addressed to plaintiff, signed by defendant and dated April 19, 1987, in which defendant discussed three or four incidents of sexual contact he had with the plaintiff when she was a child.” See Plaintiff’s Exhibit No. 5. Opinion dated November 19, 1990; District Court File No. 1:90-CV-159.

6. Pfiefle v. Hustwaite (King County Superior Court, Washington; civil settlement, 1991). Plaintiff, a 31-year-old woman, alleged that when she was a grade school student at Sky Valley Seventh Day Adventist School between 1969 and 1976 she was repeatedly raped and molested by a teacher. She recovered the memory as an adult. “Discovery revealed several other victims, whose testimony was helpful in establishing that the Seventh Day Adventist should have known of the teacher’s propensities.” Shepard’s/McGraw-Hill, Verdicts, Settlements & Tactics (1991).

7. D’s recovered memory (in 1991) of sexual abuse by her father, Stanley Huntingford, 20-34 years earlier. As summarized by Justice Thackray, “Mr. Huntingford was convicted by a jury on six counts of what is now generally called sexual assault. The charges were brought by three of his five children. Of the three, two had continuous memories of the abuse while the third, D., recovered her memory 34 years after the first assault.” Her Majesty the Queen v. Stanley Charles Huntingford (Supreme Court of British Columbia)(Vancouver Registry No. CC940539).

“The first woman [with continuous memory] said that her father regularly raped her, but stopped when she was 14 because she screamed when he came into her bedroom. She said she told her mother about the incidents in 1981….The accused’s wife, who testified for the defense, told the jury she never confronted her husband when the first daughter told her in 1981 about the abuse.” (Larry Still, “Father, 73, convicted of incest,” Vancouver Sun (February 4, 1995: A6).)

As Justice Thackray explained at sentencing, on March 28, 1995, “The Crown retained the services of Dr. John Yuille. Dr. Yuille is a psychologist and a leading expert in retention and recovery of memory. He also has impressive credentials in the area of sexual abuse. Dr. Yuille interviewed D. and prepared a report….Dr. Yuille therefore gave oral evidence in which he, in my opinion, fairly set forth the opinions of the two opposing camps. Dr. Yuille did not in any way demean the opinion of Dr. Loftus or the opinions of others with whom he parts company on the subject. Rather, he showed an objectivity that allowed both the Crown and the defence to rely upon his evidence and recommend it to the jury.” Id.

8. Hewczuk v. Sambor (Civil Action No. 91-6562, Federal District Court, Eastern District of Pennsylvania). “Hewczuk’s attorney Nancy Wasser said her client experienced vivid memories of the alleged torture after she miscarried two years ago….Records from Catholic charities and hospitals helped corroborate her client’s recollections.” (Lisa Brennan, “Abuse Victim Gets $600,000 32 Years Later; Remembered Event Two years Ago,” Legal Intelligencer, November 6, 1992. See also, Lisa Brennan, “Judge Upholds $600,000 Award in Abuse Case; Memory Suppressed for 32 years,” Legal Intelligencer, February 26, 1993: 1).
In response to post-trial motions, the judge affirmed the verdict, summarizing the evidence and findings as follows: “Viewed in the light most favorable to plaintiff, the verdict-winner, the trial evidence established that, while in defendant’s foster case for a brief period in early 1960, plaintiff was horribly mistreated (forced to eat her own vomit and drink her own urine; smeared with fecal matter and forced to eat it; bathed in extremely hot water; nearly drowned when her face was held under water in a toilet bowl; and, on at least one occasion, sexually assaulted); and that her memory of these atrocities was totally suppressed for many years. It is also clear that she regained her memory of these events, more or less fully, by June of 1991, and that she had begun to have ‘flashbacks’ and partial awareness of the earlier trauma in the summer of 1990.” (Memorandum and Order, pp. 1-2; Hewczuk v. Sambor, C.A. 91-6562 (February 18, 1993).)

9. Leonard v. Estate of Cowles (Hillsborough Circuit Court, 1993). Frank Leonard’s recollection, in therapy, of childhood abuse by his uncle, Tampa publishing executive Frank Cowles, Jr. “Records were produced showing that Cowles had been convicted in 1959 of sexually abusing young boys in Clearwater….According to the lawsuit, Leonard’s uncle admitted the abuse and then killed himself. Leonard won a settlement from the estate.” (St. Petersburg Times, March 6, 1994. See also “Abuse lawsuit target’s uncle’s estate,” St. Petersburg Times, April 14, 1993: 1B.)

10. Herald v. Hood (Summit County, Ohio, jury verdict, 1992; affirmed 1995). Julie Herald sued her uncle, Dennis Hood, alleging sexual abuse from age 3 (in 1962) through 15. The memory returned while Herald was watching her 4-year-old daughter play with a friend. Herald presented a taped telephone conversation in which her uncle indicated that she “had been the only one.” Two therapists also testified that at a meeting with Herald in their offices, he admitted sexually abusing her. She was awarded $150,000 in compensatory damages and $5 million in punitive damages. The Ohio Supreme Court recently upheld the decision. (Reginald Fields, “Witness Says She Felt Confusion and Guilt; Memory of Sex Abuse Comes Back by Observing Daughter, Court is Told,” Akron Beacon Journal, July 25, 1992: C1.)

Dennis Hood’s testimony verifying (a) that knew the subject matter of Julie Herald’s phone call and (b) that his voice and Julie Herald’s are the ones on the tape.
Complete transcript of the telephone call in which Dennis Hood acknowledges abusing Julie Herald
Dr. Devies’s testimony on the confrontation between Julie Herald and Dennis Hood in his office.
Ms. Kepler-Didato’s testimony about the same meeting, including the events immediately thereafter.

11. R’s recovered memories of being raped as many as 20 times by her neighbor in childhood, Lorne Francois. “The woman testified that she was about 13 years old when she went to the accused’s home one evening to use his living-room telephone because her family had no phone….She said Francois pulled down her pants and underwear and had sexual intercourse with her. When it was over, she said, ‘he told me not to tell anybody, or else.’” (“Prescott Child Sex-Abuse Probe,” Ottawa Citizen (April 1, 1992: p. B2).) Mr. Francois did not take the stand, and the jury reached a unanimous decision of guilty. The verdict was upheld by the Ontario Court of Appeal (1993), 14 O.R. 3d 191, with one judge dissenting due to concerns that the jury drew improper inferences from the defendant’s failure to take the stand. As stated by the majority: “The trial judge’s instructions were unimpeachable.” The verdict was also upheld by the Supreme Court of Canada ( R. v. Francois, [1994] 2 S.C.R. 827).

The most powerful corroboration of R’s claim came from Project Jericho, a massive investigation into child sexual abuse in the Prescott area. That investigation uncovered a host of other victims. Francois was found guilty in 1995 “of two sexual assault charges involving a 13-year-old boy more than 20 years ago.” (“Prescott man guilty of sexual abuse,” Ottawa Citizen (May 3, 1995: p.D1).) “He is already serving six years for sex crimes, including raping a teenage girl and sexually assaulting two teenage boys.” (Id.) Charges that Francois sexually assaulted two patients at the Royal Ottawa Hospital when he was there for a court-ordered psychiatric assessment in 1991 were dropped when the Crown failed to move with sufficient speed. (Jacquie Miller, “Child molester’s new charges quashed,” Ottawa Citizen (March 3, 1993: P. A1).)

Given Francois’s 30-year history of violent sexual attacks on children, the Crown moved in 1997 to have him declared a dangerous offender. An Ottawa court decided, however, that he was unfit to take part in the hearing. He was committed to a mental hospital instead. (Jeremy Mercer, “Pedophile unfit to take part in legal action: 69-year-old man faces hospitalization for dementia instead,” Ottawa Citizen (December 5, 1997: p. C3).)

12. Frank Fitzpatrick’s memory of prolonged child sexual abuse by Father James Porter. His personal investigation resulted in tape-recorded incriminatory statements by Porter, and eventual identification of dozens of other victims. Porter was prosecuted criminally in Fall River, Massachusetts, and he pled guilty. A civil suit against the Catholic Church was settled on terms favorable to the plaintiffs. (Robert Correia and Linda Borg, “‘I’m Sorry,’ Porter weeps; Victims, judge unmoved; he gets 18-20 years,” Providence Journal-Bulletin, December 9, 1993: 1.)

13. John Robatille’s memory of sexual abuse by Father Porter, triggered by reports about Frank Fitzpatrick. “His specific memories were confirmed by two classmates….Harvard psychiatrist Stuart Grassian surveyed 43 [of the Porter victims] in 1993 and found another 8—or 19 percent—who reported no thoughts or memories of the childhood abuse until the case broke in the media.” (Katy Butler, “The Latest on Recovered Memory,” Family Therapy Networker, Nov/Dec 1996: 36.)

14. Keene v. Edie (King County Superior Court, 1993). The jury “found that Ronald Edie, 57, of Auburn, had molested his former neighbor between 1973 and 1977….Her claims were bolstered by testimony of two of Edie’s daughters and a woman who testified he molested them when they were children.” (Richard Seven, “Psychiatry of Repressed Memories on Trial,” Seattle Times, July 9, 1993: A1.)

15. Cynthia Lewis’ memories of child sexual abuse by Rev. Alfred R. Desrosiers. Her memories were revived in 1993 when her mother, dying of cancer, expressed the wish to see Father Desrosiers, a long-time family friend. After a hearing to assess the reliability of the recovered-memory evidence, Judge Needham allowed the case to proceed. One reason “was corroborative evidence” in the form of “conversations Father Desrosiers had with Louis E. Gelineau, then Bishop of Providence, and the Rev. Normand Godin after Lewis reported her recalled memories to the diocese.” (Tom Mooney, “Why a court accept ‘recovered-memory’: While its legal validity is debate in one sexual-abuse case, a judge rules that it is reliable and admissible in a trial involving a Catholic priest,” Providence Journal-Bulletin (April 13, 1998: A1).)

16. Hoult v. Hoult (Federal District Court in Massachusetts; jury verdict, 1993). Successful civil suit against David Hoult for sustained child sexual abuse. Ms. Hoult’s claims were supported by something her mother witnessed (her father on top of another sibling in bed) and by a 13-year-old babysitter who testified that David Hoult had sexually molested her. “Other family members remembered Jennifer’s father grabbing her breasts.” (Minouche Kandel and Eric Kandel, “Flights of Memory,” Discover, May 1994: 32.) Ms. Hoult’s family sided with her, and the jury verdict was unanimous. David Hoult has since sued Ms. Hoult for libel over her subsequent statements that he had “raped” her. A federal district judge recently dismissed that suit after reviewing the trial record and concluding that “the issue of rape was decided [in Ms. Hoult’s favor] by the jury.” (Hoult v. Hoult (Civil Action No. 96-10970-RCL) (Slip opinion, p.6).)

Update: On May 13, 2002, the federal district court found that David Hoult had fraudulently conveyed over $130,000 in assets to avoid paying part of the $500,000 judgment that he owes to his daughter Jennifer. Two weeks later, the court entered an order requiring him to deposit all his income in a designated Massachusetts bank account and to limit his withdrawals from that account to cover his reasonable living expenses. David Hoult has since been found in civil and criminal contempt for refusing to comply with the order. This is the First Circuit’s most recent decision, which goes largely against David Hoult.

Jennifer Hoult has launched a website that documents the errors about her case that are contained in “Remembering Dangerously,” an oft-cited article by Elizabeth Loftus in the Skeptical Inquirer. (See Jennifer Hoult, “‘Remembering Dangerously’ & Hoult v. Hoult: The Myth of Repressed Memory that Elizabeth Loftus Created” (2005).)

17. People v. Hoffman. David Hoffman, sentenced in Poughkeepsie, New York, June 15, 1994 for sexually abusing the young daughter of his girlfriend 14-16 years earlier. “The woman’s first memory of the abuse came when she was typing a report regard a sexual abuse case,” working in a probation office in Grand Rapids, Michigan. (ErinMarie Medick, “Woman’s Repressed Memories of Abuse Leads to Conviction, Columbus Dispatch, June 14, 1994: A1). The woman eventually filed a police report, and a detective interviewed Hoffman, who had been convicted in 1986 of sexually abusing children at a children’s home in Duchess County, New York. Hoffman admitted he had committed the earlier crimes while a graduate student at Ohio State University and pled guilty as charged.

18. Gonzalez v. Boullon (Florida jury verdict, 1994). Dr. Nina Gonzalez successfully brought a civil suit against her stepfather, Luis Boullon, in Florida. “While a premed at Holy Cross College in Worcester [Massachusetts], she began to remember what she recalled as nighttime visits from her stepfather….Testimony of her little cousin and her stepmother who she told of the ‘massages’ years before also weighed with the jurors.” Gonzalez’s older brother, Ricardo, testified he had witnessed two instances of abuse. (John Lantingua, “$1 Million Award Over Repressed Memory of Abuse,” Miami Herald, February 14, 1994: 1A.)

19. Crook v. Murphy (Benton County Superior Court, Washington; Case No. 91-2-01102-5). Verdict for plaintiff by Judge Dennis Yule, February, 1994. Lynn Crook, the oldest of six children, successfully sued her father for recovered memories of childhood sexual abuse. One of her sisters testified to an abusive event she had always remembered. This decision is noteworthy for what it says about Richard Ofshe, a sociologist who testified against Ms. Crook: “Just as [Ofshe] accuses [therapists] of resolving at the outset [to find] repressed memories of abuse and then constructing them, he has resolved at the outset to find a macabre scheme of memories progressing toward satanic cult rituals and then creates them.” There is a detailed excerpt from the Los Angeles Times about how Ofshe and Watters misrepresented the facts of this case in their book, Making Monsters. Ms. Crook has written a response to Ofshe and Watters, which was published in the Journal of Child Sexual Abuse.

20. Alley v. Alley (King County Superior Court, 1994). Plaintiff successfully sued her father, William Alley, for sexual assault in her childhood. “No one in the Alleys’ family testified on the father’s behalf….[The plaintiff’s attorneys] used psychiatric records filed during William Alley’s 1970s divorce to support the family’s claim of incest and abuse.” (Richard Seven, “It Wasn’t the Money, It Was Principle; Jury says Father Raped Daughter,” Seattle Times, June 14, 1994: B1).) “In addition, an unexpected witness for the plaintiff came forward during the last week of the trial, after having read about the case in the paper, to offer testimony that when she was 12 and Julie Alley was 6, Ms. Alley told her that, ‘my daddy touched me,’ and pointed to her vagina.” (“Dentist Found Liable in Recovered Memory Case,” PR Newswire, June 13, 1994.)

21. People v. Lynch. California criminal charges against William Lynch. “Charged with 14 counts of lewd conduct with a child stemming from alleged attacks on four women when they were between 7 and 13 years old from March, 1967 to July, 1972.” One of the women repressed the memory; the others remembered the abuse ever since. (Julie Tamaki, “Abuse Case to Challenge New Law on Limitations,” Los Angeles Times, May 15, 1994: B1).

22. Chris White, whose repressed memories of sexual abuse at Ryerson Public School 20 years ago, resulted in a guilty plea by Robert Warren. “Now in his mid-50s and living in British Columbia, Warren had been with the Toronto Board of Education for 23 years and had two other convictions for sexual offenses against children. One dated back to 1965 in Lindsay; the other was in British Columbia in 1988.” (Judy Steed, “Abuse Victim…” The Toronto Star, May 7, 1995: A1).

23. Cheit v. San Francisco Boys Chorus and William Farmer (San Francisco Superior Court: civil settlement with SFBC, default judgment against Farmer, 1994) (Plumas County Criminal Court: warrant and criminal arrest, 1994). Corroborated by other victims and by tape-recorded admission. See Mike Stanton, “Bearing Witness” [three-part series] Providence Journal-Bulletin, May 7-9, 1995; see also, Miriam Horn, “Unlocking Hidden Memories,” U.S. News & World Report, November 29, 1993; “Update: Recalling the past, embracing the future,” August 4, 1997.

24. State v. Quattrocchi (Rhode Island Superior Court jury verdict; RI Supreme Court No. 95-343-C.A.). The first criminal case in Rhode Island involving recovered memory. The state presented evidence from two other girls who reported sexual assaults by Quattrocchi: one was his own goddaughter, who the defendant cornered naked in a shower when she was seven years old (in 1977). She told her parents about it when she was a sophomore in college. The other incident occurred four years later (in 1981) and resulted in a contemporaneous report to the police. The events at issue in this criminal case cover the same years as those incidents. [In Catch-22 reasoning, the Rhode Island Supreme court subsequently ruled that such evidence was “too prejudicial” and the defendant would have to be retried without such evidence. Without such evidence, many states considered this kind of testimony too unreliable—in absence of the kind of corroboration that the Rhode Island court now prohibits.]

25. Commonwealth of Pennsylvania v. Crawford. (Guilty verdict in murder case, 1995). “Franklin Crawford, 49, of Dayton was charged in May, 1994 with the murder of Pearl Mae Altman after another man said that seeing a woman who resembled the victim brought forth repressed memories of witnessing Crawford throwing the woman off a bridge.” “John Reed cried as he testified Thursday that he was 16 on Oct. 22, 1971, when he saw Crawford throw Pearl Mae Altman into the Allegheny River.” (“Man Guilty in 1971 Slaying After Witness Recalls the Drowning,” Pittsburgh Post-Gazette, February 19, 1995: D15.) A woman’s purse and shoes were found 23 years ago near the spot where he said Altman was thrown in the river. Crawford also happened to have been the prime suspect at the time. Crawford’s then-wife testified “that her husband came home that night, removed his clothes, and put them in the washer. She said it was the only time in their marriage he put clothes in the washer. She said he got dressed again and, before leaving, told her to tell anyone looking for him that she hadn’t seen him.” Lawrence Walsh, “Murder Memory Misjudged by Judge,” Pittsburgh Post-Gazette, August 11, 1996: B6. [This case was reversed on the ground that the judge did not allow testimony of a psychiatrist who would have testified about the “unreliability” of recovered memory, the corroborative case notwithstanding. The case is still pending.]

26. Thomas v. Freeman (Lee County, North Carolina, unanimous jury verdict, June 22, 1995; Case No. 93 CVS 831; upheld by North Carolina Court of Appeals, November 19, 1996; No. COA96-226). Unanimous jury verdict for Shirley Thomas against her father, Velton Freeman, “for decades-old, once-repressed memories of horrific physical and sexual abuse….Witnesses corroborated Thomas’ claims with their own memories of Freeman hitting, bruising and cursing Thomas; of him carrying her out of her bedroom at night and her returning later in tears; of Thomas being terrified of his wrath; and of Thomas’ mother leaving [the] marriage and the household in 1962 or ’63, long before her mother and sister claimed it occurred in 1966.” (See five-part series by Jill Warren Lucas, beginning with “Jury Awards $600,000 in abuse case,” Sanford Herald, June 13, 1995.)

27. D.M.M, a 39-year old Canadian actress. “Remembered repeated abuse by her family doctor when she joined Alcoholics Anonymous after years of heavy drinking….[In March, 1996] a provincial justice ordered Leo Pilo, M.D. to pay her $95,000—despite the testimony of FMSF advisory board member and psychiatrist Harold Merskey, who suggested that D.M.M. was probably suffering from “‘false memories.’” D.M.M.’s accusations were supported by four other women who said Pilo had sexually abused them in childhood. Pilo’s medical license had been previously revoked in a separate proceeding in which he admitted the women’s charges.” (Katy Butler, “The Latest on Recovered Memory,” Family Therapy Networker, Nov/Dec 1996: 36, 37). Criticism by affiliates of the False Memory Syndrome Foundation. Full text of the relevant legal documents in response.

28. Wilson v. Phillips (California jury verdict, 1996). LaDonna Wilson and her half-sister (who does not want to be identified) sued John Phillips for sexual molestation that occurred when each daughter was about 5 years old. A jury awarded $1.15 million in compensatory damages. “During the trial, Wilson, her sister and mother testified about a time when Wilson’s bed came crashing down on a box of kittens. When the others came into the bedroom, Phillips was there naked.” (David Reyes, “2 Daughters Win $1.15 Million in Sex Abuse Case,” Los Angeles Times, March 30, 1996: B1).

Update: the Court of Appeals for the Fourth Appellate District upheld the verdict of the jury, finding that Phillips sexually battered and intentionally inflicted emotional distress on his daughter and stepdaughter. Wilson v. Phillips, 73 Cal. App. 4th 250; 86 Cal. Rptr. 2d 204 (June 30, 1999).

29. Franklin v. Stevenson (Utah jury verdict, 1996). Cherise Franklin’s memories of sexual abuse by Kenton Stevenson. As documented at trial, Franklin was in and out of therapy; her flashbacks were not recovered during a therapy session. “After recording her [recovered] memories in a dated journal, Franklin hired a private detective, found Stevenson’s former wife and learned that Stevenson had been found to have abused his own children as well. At trial [in August 1996] in Salt Lake City, Stevenson’s 16-year-old daughter, Rayne Burtchin, testified that her father had sexually abused her. A stepdaughter testified that he had mutilated animals in front of her. The accounts were supported by a 1986 family court divorce and custody ruling, finding that Stevenson had sexually abused his son and two daughters and had raped one with a coat hanger.” (Katy Butler, “The Latest on Recovered Memory,” Family Therapy Networker, Nov/Dec 1996: 36, 37). The Findings of Fact established that Stevenson abused all three of his children in the other marriage. In a highly unusual move, the judge entered a judgment notwithstanding the verdict, in favor of the defendant. The case is on appeal. Note: Question No. 2 in the Special Verdict form asked “Did Cherise Franklin produce corroborating evidence in support of the allegations of abuse against Kenton Stevenson?” The jury responded: Yes.

30. Shahzade v. Gregory (Massachusetts federal district court, Docket No. 92-12139-H). Civil suit by Ann Shahzade against an older cousin for molesting her for a five-year period beginning when she was 11 years old. “Her cousin, George Gregory, a California surgeon, acknowledges he fondled her, but says he did not sexually assault her.” (Judy Rakowsky, ”Memory Expert Supports Woman,” Boston Globe, April 1, 1996: 26.) In his deposition, Gregory admitted to a series of fondling incidents that occurred over a 12-to-16-month period. (Deposition of George Gregory, May 10, 1995, pages 80-83; he admitted to additional fondling on pages 133-135.) Note: “fondling” is sexual assault under the criminal laws of virtually every state. (The full text of the decision to allow recovered memory testimony is available through Jim Hopper’s site on “Recovered Memories of Sexual Abuse: Scientific Research & Scholarly Resources.”) The defendant settled the case after this decision was rendered; there is a gag order prohibiting release of the settlement amount.

31. Martinelli v. Diocese of Bridgeport (1997 Connecticut civil jury verdict). Frank Martinelli’s adult recollections of sexual abuse by Father Laurence Brett at St. Cecilia Church in Stamford between 1962 and 1964. “Martinelli, who is married and has a young son, testified during the eight-day trial that he repressed his memory of the abuse until 1991, when it all came back to him like a ‘wave’ while he was on the telephone with a friend who told him he had also been abused by Brett as a child.” (Daniel Tepfer, “Diocese must pay; Jury awards $750,000 to victim,” Connecticut Post (August 27, 1997): A1.) “Probably the most damaging evidence of the trial was a memo of a meeting that took place among diocese officials on Dec. 2, 1964, regarding an assault by Brett on a 19-year-old male Sacred Heart University student. The memo states the teen had gone to Brett to discuss a sexual problem and Brett ended up performing oral sex on him. The memo goes on to state that Brett was being sent away for treatment, and “‘A recurrence of hepatitis was to be feigned should anyone ask,’ it read.” Id.

32. Peter VanVeldhuizen’s memories of childhood sexual abuse from 1966 to 1968 by Reverend J. Van Zweden of the Netherlands Reformed Congregation Church. VanVeldhuizen v. Netherlands Reformed Church of Rock Valley (Iowa District Court for Sioux County; 1997). VanVeldhuizen repressed the memory and did not recall the abuse until February, 1991, while undergoing psychotherapy.

To avoid litigation, Dr. VanVeldhuizen agreed to the request of the Netherlands Reformed Church to submit the claim and all related evidence to the Institute for Christian Conciliation. In a 9-page letter, the Executive Director noted that, “[I]n the twelve years that I have been working in sexual abuse cases, I do not recall meeting a more credible witness.” Dr. VanVeldhuizen introduced a variety of corroborating evidence, including (1) testimony that Rev. Van Zweden sexually abused his grandson and (2) eyewitness testimony to one of the incidents of sexual abuse of Peter VanVeldhuizen by Rev. Van Zweden. The mediator concluded that “Peter has more than met the highest biblical standard of proof, which is actually required only in capital offenses, namely, that the sin be confirmed by the testimony of at least two witnesses.”

After insisting on Christian Conciliation, the Church refused to go along with the findings. Dr. VanVeldhuizen sued and proved his case (again) in court. A Sioux County jury awarded compensatory and punitive damages, after VanVeldhuizen proved that Albert Bakker, a church official at the time, witnessed the acts but did nothing to stop them or to report them to the appropriate officials.

33. Lee Roy Donnell’s conviction for sexual battery. “Father Guilty of Assault,” Washington Post (September 10, 1992): B3.

34. State v. Warner (July, 1998). Criminal conviction for first-degree rape and for first-degree rape by instrumentation. The victim, “now 18, was 12 years old when she was molested by Warner. She told counselors of the abuses in 1997.” She recalled the events only under intensive counseling. “Judge Sends Rapist Up for 20 years,” The Daily Oklahoman (July 13, 1998), p. 3.

35. The criminal conviction of a 67-year-old grandfather in Canada, whose name was blocked from publication, for sexually assaulting four daughters over 21 years. At least one of the daughters recovered her memory as an adult. One daughter told someone at the time and had a lock installed on her bedroom door. The father ultimately begged for mercy and told the court he “had changed.” He pleaded guilty to molesting three daughters and to “violating two daughters with a wooden hand file. He blamed Satan for his actions.” This undoubtedly helps explain the ritualistic elements in the daughters’ accounts. See Ciaran Ganely, “Incest Dad Jailed for 6 Years; Born-Again Christian Begs for Mercy,” Toronto Sun (August 8, 1996), p. 19. See also Philip Lee-Shanok, “‘Guilt’ Notes Sent to Sex Victims,” Toronto Sun (June 21, 1996), p. 4.

36. T. Jeffrey Haines’ recovered memory of sexual abuse by Rev. J. Faulton Hodge of the Episcopal Diocese of Western North Carolina. “Haines, 35, claimed that Hodge repeatedly molested him and gave him drugs, alcohol and pornography for 12 years starting in 1969 when Haines was only 8, and offered assurances that ‘God will forgive you.’” Haines contended in his lawsuit, filed in August 1995, “that he repressed memories of the sexual abuse until they were brought out in therapy in 1993.” The case was corroborated by the successful claim of Jesse D. Hickan, who was molested by the priest in 1989 and 1990. Both men had evidence “that church officials—including Johnson, the bishop of the diocese, and Weinhaurer, the former bishop—knew about child sex abuse by Hodges, but conspired to hide it.” (Clark Morrison, “Lawsuit Accusing WNC priest of child sex abuse settled,” Asheville Citizen-Times (April 15, 1995), p. 1A.)

37. A criminal case based on a 28-year-old woman’s flashbacks of repeated rape by her stepfather during the 1970s. “On April 15, 1996, Associate Justice Frank J. Williams denied a motion to block certain evidence derived from the alleged victim’s ‘repressed’ memories, saying that the credibility of the evidence is a matter for the jury to decide.” (C. J. Chivers, “Ex-police captain’s rape trial set to begin this summer,” Providence Journal (April 16, 1996.) The defendant pleaded no contest to Indecent Assault of a Child on May 30, 1996. See case P1-1995-1329A in the online database on Rhode Island criminal court records.

38. Kelly Scaglione’s recovered memories of a sexual assault by Master Cpl. Harold MacLean of the Canadian Armed forces. “After repressing the memories of the assault for years, Scaglione pressed charges against McLean in 1995. McLean was convicted of indecent assault in April 1997.” McLean subsequently settled a civil case for damages. (Philip Lee-Shanok, “Army Blamed in Assault; Private Held NCO Attacker in Awe, Trial Court Told,” Toronto Sun (February 26, 1999), p. 48.’)

39. Henry Bachmann’s recovered memories of being sodomized in 1964 by Rev. James Gummersbach in the basement of the Church of Immaculate Conception in St. Louis. In March, 1999 a jury awarded $1.2 million in this repressed memory case, the first such civil trial in Missouri. The plaintiff’s lawyers introduced corroborating evidence that the archdiocese “knew of Gummersbach’s propensity to harm children and did nothing about it.” (“Man Awarded $1.2M in Abuse Case” (AP-NY-03-02-99 1504 EST).)

40. Diane Bowman’s “long-buried memories of her mother’s death [which] resulted in her father being convicted of murder.” (Adam Powell, “After 24 years a daughter’s memory sends killer to jail.” (London) Daily Mail (July 24, 2002), p. 37.)

41. Tommy Burt’s “repressed memories of abuse” by Kenneth Eugene Ward at the Eastside Baptist Church seventeen years earlier. (Kassabian, “Time lets molesters get away, mom says,” Austin American-Statesman (March 13, 2005), B1.) “William Brown, an investigator in the Rusk County District Attorney’s Office, obtained a written confession from Ward.” He pleaded guilty in 1996 to indecency with a child.

42-43. Two women in their forties whose recovered memories of sexual abuse by James A. Rogers in 1964 were corroborated by a third woman who never forgot the abuse and by Rogers’ own admission that he sexually assaulted all three girls in 1964. (See Jackman, “Man Gets Prison for ’64 Assaults,” Washington Post (August 29, 2001), B2. See also Jackman, “Man Accused of ’60s Child Abuse,” Washington Post (October 14, 2000), B2.)

44. Lt. Commander Kenneth Whitwell v. Rev. Edward J. Smith (New Castle County, DE). When Kenneth Whitwell had an argument with his wife in 2000, memories of being sexually abused as a child began to emerge. In 2003, he traced his emotional problems back to incidents of rape and sodomy. Whitwell remembered that in 1982, when he was 14 years old, Edward Smith—his religion teacher at Archmere Academy, where Whitwell was a freshman—sexually abused him. After the incident, Whitwell repressed the memory of the abuse for 18 years. When he went to confront church officials, Smith allegedly admitted to the abuse in a meeting with his supervisor, Reverend James Bagnato. Smith, who did not respond to Whitwell’s 2007 suit, in which Whitwell also sued Archmere Academy, the Catholic Diocese of Wilmington, and Rev. Michael A. Saltarelli, had started teaching at Archmere after having been removed from his position as principal at St. John Neumann High School in Philadelphia, where he was also accused of child sexual abuse. The outcome of the case: “Smith defaulted. Plaintiff’s verdict for $41 million including $6 million in compensatory damages and $35 million in punitive damages against Smith only. The Court dismissed Archmere, the Catholic Diocese of Wilmington and Bishop Michael Saltarelli as defendants in the lawsuit.” (Kenneth Whitwell v. Archmere Academy, Inc., et al.; District Court File No. 1:05-CV-00796-SLR.)

45. Brian v. Rev. Fred Lenczycki (DuPage County, IL). In 1983, when Brian was 10 years old, he was molested by his priest, Rev. Fred Lenczycki, at St. Isaac Jogues Elementary School in Hinsdale. In 1997, when Brian was in his mid-twenties, Brian started to dream about the abuse and remembered what had happened to him. Brian is not Lenczycki’s only victim—the priest admits to having molested over 30 boys in six parishes in Illinois, California and Missouri from 1974 to 1999. Over a dozen have now sued the Joliet Diocese. In response to the allegations, Lenczycki told his victims that he had been confused about his sexuality. He contends that he did not want to break his celibacy by sleeping with a woman and was not aware of the extent of his wrongdoings. After retiring and being held in custody, Lenczycki was released in 2009. He will continue his sex-offender treatment. “Brian said he settled his suit for a ‘couple hundred thousand dollars.’ He used the money to pay off his education and for a small down payment on a house. He said it wasn’t about the money, but rather to try to hold [Bishop] Imesch accountable.” (See Gutowski, “Pedophile priest’s victim: ‘You can’t have 30 victims and have remorse,’” Daily Herald (March 25, 2008).)

46. Jane Doe v. Philbert G. Pargas (Arapahoe County, Denver, CO). Between July 1997 and June 2001 Philbert Pargas allegedly assaulted a young girl who lived on his street. She did not recall the incidents until she studied recovered memories in her high school psychology class. She is one of two women to speak out against Pargas, who often had young girls over to his house between 1997 and 2007. He allegedly began to abuse the other young woman in 2003. During police questioning, Pargas admitted massaging one girl and hugging and kissing at least one other. However, he denies that the contact was sexual in nature. Pargas was arrested on November 28, 2008. In May of 2010 he was sentenced to 5 years in prison. (See Illescas, “‘Grandpa’ to neighbors, suspect to cops,” Denver Post (December 21, 2008).)

47. John Doe v. Claude Edward Foulk (LA County, CA). One of Claude Edward Foulk’s alleged victims is his foster child, whom Foulk began abusing several months after taking him into his home. Another is a 45-year-old man, who was nine years old when Foulk cared for him as a nurse. According to the first alleged victim, he and Foulk became friends, and Foulk eventually took him in as a foster son. Foulk allegedly began abusing the boy shortly after he moved in. His memories of the abuse began to reappear when he visited Napa State Hospital through his job. He spotted Foulk at the hospital, remembered the abuse, and went to the authorities. A third man also testified against Foulk, and reports of 13 more abuse cases, which involve Foulk and date back to 1965, have been reported to the authorities. In April 2010, Foulk was ordered to stand trial and was held on a $3.5 million bail. (See Deutsch, “Claude Edward Foulk: Three Men Testify to Hospital Director Molestation,” Huffington Post (April 14, 2010).)

48. Mark Blackowiak v. Richard Kemp (Supreme Court of Minnesota). Blackowiak claims to have been abused by Richard Kemp, his school counselor at Sheridan Junior High School in 1970 or 1971, when Blackowiak was 11. While the plaintiff could not remember the abuse for years, he hinted at it to his friend at the time. According to Smith Law Firm documents, “the plaintiff told his friend Steven Mayfield to “watch out for” Kemp, with whom Mayfield had been seen, because the plaintiff did not want Mayfield to be abused.” Although Blackowiak was too ashamed to elaborate further, when his mother asked him if “Kemp was doing anything “wrong” to him,” he answered that Kemp was. Even in therapy Blackowiak could not speak about the incidents and did not want anyone to know. However, when he ran into Kemp in 1981, he “freaked out”: he assumed that “Kemp was sexually abusing the boy and… felt sorry for the boy because ‘that shouldn’t happen to little kids.’” After the encounter, he “insisted he did not think anymore about the abuse he had suffered until 1991 when a conversation with Mayfield caused him to realize that his problems with drugs and alcohol, crime and with personal relationships were all the result of Kemp’s abuse.” The Supreme Court of Minnesota heard the case. (See Blackowiak v. Kemp, 546 N.W.2d 1, Review of Court of Appeals (Minn. 1996).)

49. A jury in Dover, Delaware found St. Elizabeth Roman Catholic parish grossly negligent in its failure to properly supervise then-priest Francis DeLuca and responsible for $3 million of $30 million in damages awarded to John M. Vai, who was repeatedly 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. (See blog post.)

50. Calvin Huss, of Port Deposit, Delaware, pleaded guilty to sexually abusing a 13-year-old girl over a seven-month period in 1993. The victim, now in her 30s, contacted a police after a repressed memory arose in therapy. Huss also confessed to sexually abusing a 15-year-old girl and a 17-year-old girl between 2008 and 2010. (See blog post.)

51. Bryan Bacon vs. Marianist Province of the US (St. Louis County Court). Bryan Bacon recovered memory of 1985 abuse by his Catholic high school teacher Brother William Mueller in a 2004 therapy session and filed suit in 2005. The judge ordered Mueller to pay Bacon $0.5 million dollars. Mueller has been accused of sexual abuse in 24 separate civil suits in 3 states. (See Garrison, “Bro. William Mueller: Ordered to Pay $500,000 for Sexual Assault of Vianney Student in 1980s,” Riverfront Times (August 26, 2010).)

52. Gregory Guggemos filed a suit in Lansing, Michigan against the Lansing Diocese claiming that he was abused by priest Monsignor John Slowey in the 1950s, when Guggemos was 5 or 6 years old, during his time at St. Vincent Orphanage. Guggemos received a $225,000 settlement from the Diocese in 2008. (See “Lawyer brings repressed memory action,” Michigan Lawyers Weekly (September 3, 2010).)

53. Colorado v. Marshall Adam Walker. Walker was convicted in 2007 on 30 of 35 counts of sexual abuse in the late 90s. Then a teacher at Bell Middle School in Jefferson County, CO, he abused three male students, one of whom recovered memory of the abuse in 2006 while watching a movie. The charges related to the other two victims’ abuse were added subsequently. (See judgment and sentence affirmation.)

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“False Memories”

March 22nd, 2010 Comments off

While much remains unknown about the phenomenon of recovered memories, there are still those who claim that traumatic childhood events simply cannot be forgotten at the time only to be remembered later in life. In an article promoting the so-called False Memory Syndrome Foundation (FMSF), for example, Martin Gardner asserted:

“Studies show that among children who witnessed the murder of a parent, not a single one repressed the terrible memory. Not only do victims of child incest not repress such painful memories (to repress means to completely forget the experience without any conscious effort to do so); they try unsuccessfully to forget them.” (Gardner, 1993, p. 372)

Gardner failed to cite any specific studies in support of the claim about incest. And there is only one study of children who witnessed the murder of a parent. But that study (Malmquist, 1986) is based on sixteen children, all of whom had extensive contacts with police, social workers, and family members about the tragic events they later reported as invasive. FMSF Advisory Board members have repeatedly cite the Malmquist study (see e.g., Underwager & Wakefield, 1996; Ofshe & Watters, 1994; Loftus, 1993). The Malmquist study is also cited in legal briefs filed by the FMSF. Indeed, the New Hampshire Supreme Court, the only court to side with the FMSF’s stated desire to ban recovered memory testimony from court, cited the Malmquist study with approval (State v. Hungerford, 1997). But one would never expect those children to block out the memory. More likely, it would be cases where there were not social workers and other support mechanisms in place, supporting and reinforcing the memory. The relevant comparison would be children who witnessed a murder and, as occurs often with sexual abuse, were told in some manner not to tell anyone. Such cases exist. Enterprising reporters or others interested in testing the existence of such evidence could explore various murder cases that are not included in this archive.

Dr. Paul McHugh, a psychiatrist and False Memory Syndrome Foundation Advisory Board member, echoes this untempered position, claiming that “severe traumas are not blocked out by children, but are remembered all too well” (Washington Post, 1993). When asked point blank “Can a child forget sustained sexual abuse?” on CNN (Transcript 302-1; May 3, 1993), Dr. McHugh replied “No” — apparently basing his conclusion on children he had observed at Johns Hopkins with continuous memory. Fellow psychiatrist and FMSF Advisory Board member John Hochman similarly claims that “memories of emotionally charged events are among the least forgettable memories we have” (Hochman, 1994b, p. B3). “For those who were in Nazi concentration camps or underwent torture as POWs in Vietnam, this can become a serious lifelong problem” (Hochman, 1994a, p. 17).

Of course, nobody contests the existence of invasive memories for some, even most, victims of severe trauma. The question is whether that phenomenon eliminates the possibility of the opposite reaction: no conscious memory of the trauma until later in life.

False-memory partisans avoid the question with a rhetorical sleight of hand. Retired English professor and FMSF Advisory Board member Frederick Crews, for example, has constructed a “logic” whereby corroborated cases of recovered memory cannot exist in reality because that contradicts his theories about Freud. Cognitive psychology professor Jennifer Freyd demonstrated the circularity of this position (Freyd, 1996, pp. 12-14). Less extreme “skeptics,” who allow that cases of recovered memory might exist, often report finding few, if any, actual cases. For example, Loftus (1993, p. 524) notes that “claims of corroborated repressed memories occasionally appear in the published literature.” She proceeds to cite one case from 1955 that she finds less than convincing. In a similar vein, psychology professor John Kihlstrom, a former FMSF Advisory Board member, rejects cases cited in support of the trauma-memory argument because of “the general lack of independent verification of the ostensibly forgotten memories” (Kihlstrom, 1995, p. 63). PBS producer Ofra Bikel reached a more extreme conclusion, reporting that after almost a year of research she could find “only one case where a claim of recovered memory could be backed up by anything more substantial than a woman and her therapist believing it so” (Johnson, 1995). That claim caused the launch of this website.

References
Cheit, R. (1995). Letter to Ervin Duggan. Reprinted in Moving Forward, 3(3), 8-11.

CNN, “Repressed memories stir difficult questions,” Transcript 302-1 (May 3, 1993).

Freyd, J. (1996). Betrayal Trauma: The logic of forgetting childhood abuse. Cambridge, MA.: Harvard University Press.

Gardner, M. (1993, summer). “The False Memory Syndrome,” Skeptical Inquirer, pp. 370-375.

Hochman, J. (1994a, January 10). “Buried Memories Challenge the Law.” National Law Journal, pp. 17-18.

Hochman, J. (1994b, January 1). “Recovering Memories: Emotionally charged events are among the least forgettable,” Pittsburgh Post-Gazette, p. B3.

Johnson, S. (1995, April 3). “Past Imperfect: ‘Divided Memories’ casts skeptical eye on repressed-memory movement,” Chicago Tribune, p. C3.

Kihlstrom, J. F. (1995, March). “The trauma-memory argument,” Consciousness and Cognition, 4(1), 63-7.

Loftus, E. (1993. May). “The Reality of Repressed Memories,” American Psychologist 48, 518-537.

Malmquist, C. P. (1986). “Children Who Witness Parental Murder: Posttraumatic Aspects,” Journal of American Academy of Child Psychiatry 25, 320-326.

Ofshe, R. & Watters, E. (1994). Making Monsters: False memory, satanic cult abuse and sexual hysteria. New York: Charles Scribner’s Sons.

State v. Hungerford, 697 A.2d 916 (1997).

Underwager, R. & Wakefield, H. (1996). “Therapeutic Influence in DID and Recovered Memories of Sexual Abuse,” Issues in Child Abuse Accusations 8(3/4), 169-169.

Washington Post. (1993). “Skeptics question sex abuse memories,” Reprinted in Providence Journal-Bulletin (November 26), p. A7.

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