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Psychology of Consciousness: Theory, Research, and Practice © 2015 American Psychological Association

2015, Vol. 2, No. 2, 153–169 2326-5523/15/$12.00 http://dx.doi.org/10.1037/cns0000044

False Memories in Therapy and Hypnosis Before 1980

Lawrence Patihis and Helena J. Younes Burton


University of California, Irvine

To determine the extent to which false memories occurred in therapy or hypnosis


before the “Memory Wars” controversy, we examined the early history of the phe-
nomenon before 1980. We found evidence of perception distortion from the early
hypnotists and mesmerizers, but only circumstantial evidence of memory distortion.
The earliest firm evidence of false memories we found was during Bernheim’s hypnosis
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.

in 1884. After this date, we found additional evidence of varying strength, from
This document is copyrighted by the American Psychological Association or one of its allied publishers.

memories of infancy that may be false, to episodic memories of past lives and alien
abductions that are certainly false. Other strong evidence included 19th century evi-
dence of hypnotists deliberately distorting memory, and their acknowledgment of doing
so. We discuss how this evidence is consistent with recent false memory research. We
suggest that without knowledge of the history of false memory formation, clinicians
could be vulnerable to repeating the mistakes of the past.

Keywords: autobiographical memory, false memory, hypnosis, mesmerism, therapy

“Those who cannot remember the past are condemned ously described evidence of false memory pro-
to repeat it.” duction in therapy during the 1980s and 1990s
George Santayana (1905, p. 284)
(e.g., Goldstein & Farmer, 1993; Loftus & Ket-
In the light of the heated debate about repressed cham, 1994; Ofshe & Watters, 1994; Pender-
memory in the 1990s (sometimes called the grast, 1996; Maran, 2010; Yapko, 1994), rela-
‘memory wars’; see Crews, 1995), recent false tively little has been written about false
memory and reconsolidation research (e.g., Patihis memories before this era. Rosen, Sageman, and
et al., 2013; Nader, Schafe, & Le Doux, 2000), Loftus (2004) outlined one early case of possi-
and the realization that some therapies in the ble false memory from the hypnotist Bernheim
1980s and 1990s produced false memories, we in the 1880s, but did not document other evi-
address the question of whether there is evi- dence. Although others have investigated the
dence for false memories in therapy or hypnosis history of repressed memory (e.g., Esterson,
before the 1980s. Although others have previ- 2001; Crews, 1995; Pope, Poliakoff, Parker,
Boynes, & Hudson, 2007) and early hypnotism
(e.g., Ellenberger, 1970; Kihlstrom, 2002; Lau-
rence & Perry, 1988; Moll, 1889; Pintar &
This article was published Online First March 30, 2015. Lynn, 2008), to our knowledge, few previous
Lawrence Patihis and Helena J. Younes Burton, Depart-
ment of Psychology and Social Behavior, University of
researchers have carefully examined and com-
California, Irvine. piled in a single source the early history of a
Lawrence Patihis is now at Department of Psychology, related but different topic: false memory in ther-
University of Southern Mississippi. apy and hypnosis.
Many thanks to suggestions and comments on this topic
and article from scholars with expertise of the history of
In this article, we provide examples of mem-
therapy and hypnosis, including Steven Lynn, John Kihl- ory distortion in psychotherapies, hypnosis, and
strom, Jean-Roch Laurence, Frederick Crews, Harald Mer- their precedents, based on a search of the pre-
ckelbach, and Edward Shorter. Thanks to Elizabeth Loftus 1980 literature. We report findings that range
for her support of our Undergraduate Research Opportuni-
ties Program Fellowship project at UC Irvine. This research
from the debatable (e.g., infantile memories that
was also supported in part by the National Science Foun- may be false) to memories that are almost cer-
dation Graduate Research Fellowship Program. tainly false (e.g., memories of past lives).
Correspondence concerning this article should be addressed Modern research on memory suggestibility
to Lawrence Patihis, Department of Psychology, University of
Southern Mississippi, Owings-McQuagge Hall, 231, 118 Col-
had precedents in works such as Ribot (1887),
lege Drive, #5025, Hattiesburg, MS 39406. E-mail: Bernheim (1884), Binet (1900), and others.
lpatihis@gmail.com Bartlett (1932) was one of the first to suggest
153
154 PATIHIS AND YOUNES BURTON

and document that memory is reconstructive person client accounts, involving autobiograph-
and influenced by cultural expectations and ical or episodic recall in therapy, hypnosis, or
schemas that distort memory. Laboratory evi- precedent proto-therapies such as mesmerism.
dence of false memories accumulated further in We initially searched before the year 1980 only
the 1970s, but mostly for details in a slideshow and read original texts in both French (second
or a video (e.g., Loftus & Palmer, 1974; Loftus, author whose first language is French) and Eng-
Miller, & Burns, 1978). It was not until subse- lish (both authors). We found that approxi-
quent research, such as Laurence and Perry’s mately 100 years ago, words or phrases such as
(1983) study of false memories in hypnosis, and “pseudomemory,” “retroactive hallucination,”
later Loftus and Pickrell’s (1995) demonstration and “phantasy” were commonly used to refer to
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that it was possible to implant memories of what we now call false memories. Moreover,
This document is copyrighted by the American Psychological Association or one of its allied publishers.

entire events, did some certainty regarding the more than 100 years ago the term “false mem-
ability to implant complex memories emerge. ory,” or more precisely “fausse mémoire” in
With the identification of memory distortion French, sometimes was used in a context related
techniques that followed, ranging from guided to déjà vu, with closer inspection revealing a
imagery (Garry, Manning, Loftus, & Sherman, meaning of the term that diverges somewhat
1996) to associated word lists (Roediger & Mc- from current usage (e.g., in French see Sollier,
Dermott, 1995) and suggestions regarding non- 1892, p. 14; Arnaud, 1896, p. 516; in English
existent news footage (Crombag, Wagenaar, & see Berrios & Hodges, 2000, p. 328). We also
Van Koppen, 1996), it became clearer that false incorporated feedback from knowledgeable
memories could be induced with a variety of scholars in the area of memory and hypnosis,
methodologies. The fact that vulnerability to and we examined historical reviews of early
memory distortion occurs in children (Suther- hypnosis and therapy. Importantly, our search
land & Hayne, 2001), young adults (Loftus, revealed no prior scholarly source that provided
Miller, & Burns, 1978), older adults (Wylie et a detailed review or compilation of early evi-
al., 2014), and even in individuals with superior dence of false memory production in therapy.
memory (Patihis et al., 2013), implies that sus- We excluded a substantial amount of material
ceptibility to memory distortion may be a fun- that did not meet our criteria. For example, we
damental aspect of the human mind that existed only searched in the domains of psychological
long before the decades in which these studies therapy, hypnosis, and their precedents, which
were done. In light of such research, it is rea- for the purpose of this article, we define loosely
sonable to hypothesize that if we were to look to include interventions such as mesmerism-
for evidence of false memories in therapy many related practices and drug therapy. For this rea-
years before these discoveries, we would dis- son we excluded comments on the unreliability
cover such evidence. If we succeed in doing so, of memory by early Greek philosophers or
it could shed light on the precedent causes of the Shakespeare, or possible hallucinations apart
memory wars, specifically providing insight from therapy (such as in medieval witch trails or
into early interventions that provided the theory during religious miracles). We also excluded
and techniques that subsequently influenced possible yet not definitive confabulations, such
therapies in the 1980s and 1990s. as Levinson’s (1965) use of hypnosis to recall
In this article, we categorize evidence into spoken words while the patient experienced
subheadings ranging from the weakest evidence general anesthesia (cf. Cheek, 1959) and
(early hypnosis) to the strongest (recovered Grinker and Spiegel’s (1943) use of “truth se-
memories of impossible events). Within each rum” drugs in “narcosynthesis” to recover re-
subheading, we organize the evidence chrono- pressed memories of war-related events (see
logically with the earliest evidence first. First, also Kihlstrom, 1998; Horsley, 1936). What
we briefly detail our method and delineate the these excluded examples have in common is the
scope of the article. recall of “previously unaware of material,”
which could be indicative of false memories,
Method, Scope, and Inclusion Criteria yet unlike some of the events we document
later, could plausibly have occurred: only the
To compile evidence for false memories, we assumption that repressed memories are impos-
searched for historical accounts, especially first sible would render the memories false.
FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980 155

Figure 1 illustrates a timeline of milestones ment similar in some ways to mesmerism) in


related to the early history of false memories, which we find evidence of perception distortion.
which we examine in greater detail in the sec- For example, while treating patients Gassner
tions that follow (1 through 7, below). In Sec- seemed to distort the beliefs and perceptions of
tion 1, we discuss the relative paucity of evi- his patients by suggesting the devil was within
dence in early mesmerism and hypnosis, them and causing certain parts of their body to
although there is no lack of evidence of percep- shake (see Laurence & Perry, 1988, p. 6; Ellen-
tion distortion. In subsequent sections the evi- berger, 1970, p. 54), but there seemed to be little
dence becomes progressively stronger. attempt to distort memories. Distortion of per-
ceptions was reported specifically in one case in
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Section 1: The Weak Evidence From the which the patient, Emilie, was neither able to
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Earliest Hypnotists hear or see while in the trance state, despite


having her eyes open (Laurence & Perry, 1988,
Some scholars, especially those familiar p. 21). According to Figuier’s (1860, p. 136)
with the early history of mesmerism and hyp- transcript of Emilie’s exorcism, the phrases
notism, may be surprised to learn that we used were “nihil modo audiat” (nothing can be
found a lack of evidence of false memory heard) and “apertis oculis nihil videat” (nothing
production during the late 1700s and early to is seen through open eyes). Perhaps Gassner’s
mid-1800s. Still, we did identify interesting treatment is less a direct precedent of false
precedents of false memory formation, such memory cases and formation and more of an
as perception distortion and the gradual emer- early foreshadowing of the satanic or multiple
gence of issues concerning memory in mes- personality cases of the 1980s.
merism, including posttrance amnesia. In- In investigating Mesmer, we examined two
deed, we regarded the question of whether we books in the original French text (Mesmer,
would find evidence of pseudomemories in 1779, 1781), an English translation of Mes-
early hypnosis and its precedents as open, mer’s (1980) work, as well as De Horne’s
given that proto-therapies did not devote as (1780) criticism of Mesmer. These texts indi-
much attention to memory as later therapies. cate that although suggestion was used, it was
In this article we stretch the domain of hyp- employed to suggest cure rather than induce
nosis to include precedents such as Johann memory. Memory distortion could have hap-
Gassner’s exorcism treatment of 1775 (a treat- pened accidently with Mesmer, but it was not

Figure 1. Timeline of false perceptions or memories in therapy before 1980. In this


representation the intervals between dates are not to scale. See the sections that follow for
more details. Note that this diagram is selective and should not be taken as evidence that false
memories were isolated incidents. Instead, the timeline is designed to help the reader navigate
this particular article. See the online article for the color version of this figure.
156 PATIHIS AND YOUNES BURTON

well documented, nor was it his aim to retrieve As we have shown, there are clear indications
memories. It is possible that Mesmer induced of perception and belief distortion in the earliest
false perceptions using suggestion in a blind mesmerizers and hypnotists, but little evidence
patient named Maria Paradis, who allegedly re- of false memories. Next, we discuss evidence
ported seeing images and then subsequently re- that is stronger than what we have presented so
ported becoming blind again (Pattie, 1979). The far; that of therapy-recovered memories of
distortion of perceptions seems to predate mem- events before the age of three.
ory distortions in trance-inducing treatments
and perhaps was an important step toward the Section 2: Memories Before Age 3
development of false memory in later therapies.
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The Marquis de Puységur modified Mes- Infantile amnesia of episodic memory in


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mer’s techniques in ways that incorporated adults is relatively well documented and ap-
more aspects of memory. For example, Puysé- pears to be caused by brain maturation and
gur was one of the first mesmerizers to consis- language development during childhood (Howe
& Courage, 1993; Josselyn & Frankland, 2012;
tently claim that his patients developed amnesia
Nadel & Zola-Morgan, 1984). If recollections
of the trance state afterward (although Mesmer
before age two or three (i.e., the onset of infan-
may have already observed this; see Laurence &
tile amnesia) were not known to an adult client
Perry, 1988, p. 112). Nevertheless, in our read-
before therapy, they are highly indicative of
ing of the original French texts (Puységur, 1809,
memory construction and distortion.
1811, & 1812), as well as more contemporary In one of the earliest reports of such infantile
descriptions (Ellenberger, 1970; Pintar & Lynn, memory recovery, Sigmund Freud rather fleet-
2008; Laurence & Perry, 1988), we only could ingly implied that some of his patients recalled
find circumstantial evidence of memory distor- reports of trauma as early as six months of age.
tion. In one case, Puységur (1812) treated a boy, For example, Freud wrote, referring to one of
Alexandre, who in the mesmerized state re- his adult patients, “when the girl was six to
membered that “On m’a ôté de la cervelle” seven months old (!!), her mother was lying in
(some of my brain was removed; Puységur, bed, bleeding nearly to death from an injury
1812, p. 21). This could be a false memory, inflicted by the father” (Freud, 1897/1985; p.
given Alexandre’s father’s insistence that “ce 289; Freud’s original exclamation points
n’était pas l’opération du trépané” (it was not a shown). Freud made several other references to
trepanation surgery, p. 21). Nevertheless, it is early memories. For example, he also reported
difficult to distinguish whether this was merely that an adult patient remembered “the first half
a false belief or an actual false episodic memory of her second year, she saw herself sucking at
on the part of the boy. the nurse’s breast” (Freud, 1901/1953, p. 52).
In reading Scottish surgeon James Braid’s Although further searches of Freud’s work
(1943) work on hypnosis, we again found evi- failed to uncover evidence of the types of im-
dence of perception distortion (e.g., reduction of possible or highly implausible memories that
pain sensations, p. 241; inducing sensation of we document in later sections, there are further
drunkenness, p. 45) but not false memory. De- clues that he may have created false memories.
marquay and Giraud-Teulon (1860) similarly For example, Laurence, Day, Gaston, and Lynn
demonstrated perception distortion, especially (1998) identified the following excerpts where
pain perception reduction (p. 19) and image Freud demonstrates how he was persistently
induction (p. 21). Another case of Demarquay insistent that recovered memories were real,
and Giraud-Teulon described a woman who even when his patient told him the incidents had
while hypnotized “disclosed personal secrets, so not actually occurred:
serious, so dangerous to herself, that it was our There are cases, too, in which the patient tries to
responsibility to wake her” (Philips, 1860, p. disown [the memory] even after its return. ‘Something
160). It is unclear, though, whether she was has occurred to me now, but you obviously put it into
confabulating or not. It is possible this was a my head.’ . . . In all such cases, I remain unshakably
firm. I . . . explain to the patient that [these distinctions]
distorted recovered memory, but it is also pos- are only forms of his resistance and pretexts raised by
sible that the woman merely disclosed an event it against reproducing this particular memory. (Freud,
that she had remembered all along. 1893–1895/1953, pp. 279 –280)
FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980 157

Even when the analyst fails to uncover a false 1970; p. 110). Nevertheless, there is even stron-
episodic memory, Freud wrote that at the very ger evidence of false memories to document
least the analyst should encourage a strong be- from these and other authors in the next section.
lief in the patient that some major event has
been repressed: Section 3: Memories of Birth or Womb
Quite often we do not succeed in bringing the patient to
recollect what has been repressed. Instead of that, if the Because the brain is still immature around
analysis is carried out correctly, we produce in him an birth, exhumed episodic memories of perinatal
assured conviction of the truth of the construction or prenatal life could well be good evidence of
which achieves the same therapeutic result as a recap-
false remembrances. Austrian psychoanalyst
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tured memory. (Freud, 1937/1953, pp. 265–266)


Otto Rank (1924, 1929), originally Freud’s
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These excerpts are somewhat ambiguous, and mentee, proposed the idea that birth itself was a
therefore it is difficult to be sure of the extent to major trauma, reflecting an important psycho-
which Freud implanted false memories. logical change. According to Rank, people un-
Although Freud appears to be one of the first consciously aspire to return to their mother’s
to uncover infantile memories, many others womb in an ultimate attempt to overcome their
continued the practice long after Freud devel- birth trauma. Despite this theoretical proposal
oped doubts about the utility of such practice and his practicing of psychoanalysis, we could
(starting in Freud, 1905). For example, in the not find a case study of one of Rank’s patients
1920s the American psychiatrist Anita Muhl reporting an episodic memory of birth. It is
used a technique involving gazing into crystals uncertain, then, that Rank induced false memo-
and “involuntary” writing to help her patients to ries of birth. Nevertheless, he may have influ-
recover early memories. For example, Muhl enced others who later reported birth memories
(1924) regressed a 15-year-old female, Marjory, more explicitly.
who recalled: “[Melda] was very sorry for what The earliest evidence of memories of birth we
she did and she cried to take care of me and that found came from L. Ron Hubbard’s (1950) Di-
was when I was two and a half years old” anetics book. For example, the author describes
(Muhl, 1924; p. 269). The same patient also a patient who “under drugs, went back to his
recalled the following from 15 months of age: birth.” During the reliving, he “suffered the pain
and fought the doctor who had tried to put drops
I see a child playing on the ground. I can’t see what she
is doing. Now she is getting up and turning out the
in his eyes” (Hubbard, 1950; p. 86). Even more
water. Now she is going into a door. She is inside the remarkable are the author’s descriptions of pre-
house now. The picture is fading. (Muhl, 1924, p. 270) natal memories and the idea that recording of
memory engrams begins very early:
Notice the present tense usage of the patient
indicating that the memory was coming back to And suddenly it was discovered that recording begins
her, a pattern repeated in several examples in in the cells of the zygote—which is to say, with con-
ception. That the body recalls conception, which is a
the current article. The patient also recalled that high level survival activity, has little to do with en-
in this same incident she was “just beginning to grams. Most patients to date sooner or later startle
walk” (p. 270). It is clear that Muhl believed themselves by finding themselves swimming up a
that she was regressing patients to experience channel or waiting to be connected with. The recording
is there. (Hubbard, 1950, p. 88)
actual memories. For example, she wrote that
her therapy was a method of “recalling forgot- As is true of other types of false memories,
ten incidents” (Muhl, 1924; p. 264). As such, hypnosis seems to be implicated in a number of
Muhl’s therapy might be considered an early reports of birth and womb memories. For ex-
example of memory recovery therapy, although ample, British psychiatrist Denys Kelsey used
there is some uncertainty regarding whether hypnotic age regression to recover a memory in
these events are actually false. patient “Miss F” of her life in her mother’s
Here we have provided a few cases of infan- womb. Miss F, during hypnosis, reported that “I
tile memory recovery in therapy before 1980. A am very tiny . . . This is the womb” (Kelsey,
few other writers have also reported memory 1953; p. 217). As before, notice the use of the
recovery of events in the first 2 years (e.g., Grof, present tense indicating a “memory” being ex-
1976, p. 65; Hubbard, 1950, p. 169; Janov, perienced almost like a reliving episode. Miss F
158 PATIHIS AND YOUNES BURTON

went on to report that “there is something beat- I saw myself being conceived in her belly. Next scene
ing in me and through me- my mother’s heart. I she is in the hospital having the baby. Only this . . .
baby is ME. I am born strangled by the umbilical cord.
can’t see and it feels as if I’ve got no mouth” (p. Mommy is yelling, “Die . . . I don’t want it. Let it die.”
218). Another patient (Mrs. M) regressed back (Janov, 1970, p. 186)
to her “7th month” in her mother’s womb. She
describes a burning sensation that she attributes Later, Gary adds “finally I was born! I was
to an attempted abortion from her mother. breathing. I also remembered I was being held
Kelsey writes “she was quite certain that the around the ankles upside down” (p. 197).
burning was due to something which her mother Czech psychiatrist Stanislav Grof used com-
was doing to try to get rid of her” (p. 219). pletely different methods, albeit with similar
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results, in his lysergic acid diethylamide (LSD)


Later, she reaches a birth memory where she:
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therapy. This therapy involved a combination of


Felt someone get hold of her legs and pull them out. ingestion of the hallucinogen LSD and psycho-
Then something hard and painful got hold of her head therapy methods. For example, a patient (a psy-
and began to twist it. Then she was lying on something
white and felt she was choking from something round
chiatrist himself) remembered being in the
her neck. She was aware of a man and a woman, both womb:
dressed in white, and someone shrieking, “I don’t want I was greatly reduced in size, and my head was con-
her! I don’t want her!” (Kelsey, 1953; p. 219) siderably bigger than the rest of my body and extrem-
ities. I was suspended in a liquid milieu and some
Kelsey also described recovery of experi- harmful chemicals were being channeled into my body
ences as far back as conception. Kelsey de- though the umbilical area. Using some unknown re-
scribed that a patient “Mr. A” had “eventually ceptors, I was detecting these influences as noxious and
reached his conception, in which he saw himself hostile to my organism. (Grof, 1976, pp. 111–112)
as the ovum being raped, rather than wooed, by This same patient visualized his conception
the overanxious sperm of his overanxious fa- and uterine development: “to my utter astonish-
ther” (Kelsey, 1953, p. 221). The fact that ment, I relived my own conception and various
Kelsey (1953) claims that he is open to the stages of my embryological development”
possibility that these memories might be “phan- (Grof, 1976; p. 113). Even more surprising, the
tasies” (p. 216) does not diminish the evidence patient went on to say “while I was experienc-
that false memory production occurred in ther- ing all the complexities of the embryogenesis,
apy long before the 1980s and 1990s. with details that surpassed the best medical
David Cheek (1974, 1975; see also Cheek & handbooks, I was flashing back to an even more
LeCron, 1968) also appears to have induced remote past, visualizing some phylogenetic ves-
birth memories in patients. Cheek’s method in- tiges from the life of my animal ancestors”
volved hypnosis as well as techniques derived (Grof, 1976; p. 113). Grof goes on to describe
from “ideomotor” theory—the idea that uncon- other case studies of patients who reexperienced
scious body movements can signal state-bound intrauterine events while under the influence of
memories. Cheek (1974) suggested that the ob- LSD (Grof, 1976; p. 136, 161, 236). It is unclear
servation of automatic bodily movements that whether it was the hallucinogenic effects of the
resembled those of a baby struggling to be born drug that aided the visualization of these mem-
were evidence that age regression may be un- ory constructions, the therapeutic techniques, or
covering valid memories. a combination of these potential influences.
In the 1960s and 1970s, other therapists, of- Many of the examples in this section provide
ten using different techniques, also reported strong indications of false memory production
memories of birth and intrauterine experience. because they involve episodic memory recall
For example, American clinical psychologist during the infantile amnesia period. They also
Arthur Janov, instead of using hypnosis, used a reflect the dubious proposition of an infant un-
technique of ostensibly blocking client’s neu- derstanding and encoding language before the
rotic defenses that eventually led back to the perinate had mastered language perception.
reliving of their early traumatic events. Janov This section and the one that follows on implau-
reported a case study of a patient ‘Gary’ who sible satanic abuse provide similarly strong ev-
was reported to have said: idence of false memory production in therapy.
FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980 159

Section 4: Satanic Ritual Abuse Hell and introduced his “armies of the living
dead”:
Although there are historical precedents of
There’s people with no arms that are bleeding . . . There’s
alleged satanic ritual abuse activity, they either people with no eyes, and they’re bleeding from their eyes.
did not meet our criteria of being induced by There’s people that’s got no noses! And there’s people
therapy or hypnosis, or they did not involve that got ears cut off. (p. 244)
episodic memory recovery (e.g., medieval witch She also remembered a sacrifice of a girl by
trials, Nathan & Snedeker, 1995, p. 31; Goode Satan himself (p. 249).
& Ben-Yahuda, 1994, p. 57). The first case that Given the supernatural aspects of some of
did meet our criteria was the famous case pre- these memories, they are likely indicative of
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sented in the book Michelle Remembers (Pazder false memory formation during the hypnotic
This document is copyrighted by the American Psychological Association or one of its allied publishers.

& Smith, 1980). In 1973 an adult patient, Mi- sessions. Even without the supernatural aspects,
chelle, started therapy with Canadian psychia- several investigations found no corroboration of
trist Laurence Pazder, and through hypnosis the events portrayed in the book (e.g., see Allen
subsequently recovered severe satanic ritual & Midwinter, 1990; Grescoe, 1980; Nathan &
abuse memories (beginning in 1976). Michelle Snedeker, 1995; Spanos, 1996). One possible
recovered memories of a 2-year period (when alternative explanation is that the authors delib-
she was ages 5–7) in which she remembered erately fabricated the stories, without actually
being in a satanic cult with her mother. She had having visual “memories,” perhaps to help sell
no memory of this before therapy. Her revela- books. Whatever the evidentiary value for
tions included a series of sacrifices and canni- memory distortion, it is entirely possible that
balistic rituals: this book influenced other satanic ritual abuse
scares that followed in the 1980s and 1990s,
He’s pushing on my tummy. It feels like my insides are
going to squish out. The nurse is doing something
such as the McMartin preschool and Faith Cha-
down below. I want to see if my insides are coming out pel Church cases, and by extension contributed
. . . I looked down, and there was this little thing lying to the memory wars of the 1990s. A number of
there . . . it was a baby! A baby!! No! He stabbed the authors have noted that there is very little sub-
baby with it! Not with that, no! You can’t stab the baby stantial evidence for most, if not all, cases of
anymore, it’s just a mess. They rubbed it all over me satanic ritual abuse. For example, Lanning
. . . the baby. On my face, my chest. (Pazder & Smith,
1980, pp. 125–126) (1989), in a report for the FBI, concluded that
there was a general lack of physical evidence
Michelle also recalls being kept captive and for allegations of ritualistic Satanic cult activity
naked in a cage “with snakes [that] weren’t (see also Nathan & Snedeker, 1995).
poisonous.” (Pazder & Smith, 1980; p. 141).
In another session, she recalls being taken
into a room where several bodies were seen Section 5: Memories of Past Lives
on stretchers. They seem alive, she says, and
The most convincing evidence for false
when a doctor came in the room he picked memories in therapy pertains to memories that
metal knives and started dismembering the are widely considered to be scientifically im-
bodies; “He cut off its feet! . . . I can hear him possible. Although some early civilizations be-
cutting its legs. I can hear him cutting the lieved in reincarnation and some contemporary
bones up” (p. 177). religious communities continue to adopt such
As unlikely as they are, the events so far are beliefs, until recently, it was a uncommon for
at least physically possible. Nevertheless, Mi- people to claim that they could remember past
chelle goes on to describe memories of super- lives. Some forms of Buddhism hold that only
natural beings. She describes how Satan was individuals under the age of six can remember
summoned and eventually removed Smith’s past-lives. Hinduism also involves a belief in
scars, thus erasing any evidence of the alleged reincarnation. Following the migration of a
abuse, and also erased her memories of the number of Indian gurus to Europe at the end of
events “until the time was right” (Pazder & the 19th century, interest in past lives thrived
Smith, 1980; p. 242). Michelle also describes a and then morphed into the idea that adults can
memory of when Satan took her on a visit to remember past lives.
160 PATIHIS AND YOUNES BURTON

Perhaps influenced by precedents in Hindu- (1952) hypnotized Virginia and gradually re-
ism and Buddhism, one of the first cases to gressed her back to her childhood, then before
involve memories of past lives appears to be birth and eventually he regressed her one step
that observed by Théodore Flournoy, a profes- further, into a previous life (Bernstein, 1952).
sor of psychology at the University of Geneva. Virginia remembered being Bridey Murphy
Flournoy (1899/2007) observed a purported (1798 –1864) a housewife living in Cork, Ire-
psychic medium recall/experience reincarna- land. Her first memory of her life as Bridey
tions as a Hindu, as Marie Antoinette, and as a started when she was 8 years old. She recounted
being on the planet Mars (to be discussed fur- her childhood with her dad who was a barrister.
ther in the next section). Flourney’s report of She remembered her marriage with a man
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this trance-like state, although not exactly uti- named Brian when she was 17. She described
This document is copyrighted by the American Psychological Association or one of its allied publishers.

lizing hypnosis or therapy, could have influ- Bridey’s own death as well, when she fell from
enced subsequent early examples of past life a horse. She was even able to recall her funeral:
memories during hypnosis in the early 1900s. “[I was] 66 when I died. I watched them ditch
For example, Albert de Rochas, a military my body.” (Bernstein, 1952; p. 161). She re-
man who practiced hypnosis, described a person called the visual image of the date on her tomb-
he worked with in 1904. De Rochas (1911) used stone: “[It] was on the tombstone . . . I see one
hypnosis to regress a patient, Josephine, back to eight six four. Bridget . . . Kathleen . . . Mac-
previous lives. Josephine then remembered life Carthy. One . . . seven . . . nine . . . eight . . . a
as a man born in 1812 (p. 38), then a little girl line and then . . . one-eight-six and four.” (Bern-
who died at a very young age, and later as a man stein, 1952; p. 161). Bernsteins’s book contains
who had killed and robbed (p. 40). Most inter- many other rich and detailed purported autobi-
estingly, she eventually regressed down the ographical recollections from the past life. The
evolution chain and remembered life as an ape patient, Virginia, and Bernstein seemed con-
(p. 41). De Rochas did not stop his demonstra- vinced of the truthfulness of Virginia’s past life
tion there; he “progressed” Josephine into the memories. The Bridey Murphy case attracted
future. He called this technique “precognition.” criticism within a few years of publication, in-
He asked Josephine to describe her life when cluding Kline’s (1956) compilation of skeptical
she will be 40 years old. She seemed to form a essays, which included psychiatrist Harold
“memory” of the future in which she has a baby Rosen describing the case as “pseudoscience”
with a man named Eugene F, but the baby died, (p. xv). A Life magazine article also cast doubt
and then Eugene married another woman. When on the case, noting failed attempts to find evi-
de Rochas attempted to progress the patient dence of Bridey Murphy’s birth or death records
further in time, Josephine fell on her back, to the (Brean, 1956).
ground. In this future “memory” she was dead, The popularity of the Bridey Murphy story
and she witnessed her own funeral (p. 43). and Bernstein’s (1952) book, along with earlier
Perhaps even more incredible, if that is pos- accounts, may have led to subsequent past life
sible, are the memories of another patient of de memory recovery. For example, hypnotherapist
Rochas, Madame Roger. During a hypnotic ses- Dr. Arnall Bloxham regressed a patient, Jane
sion in 1905 she recalled being in the state of a (age 30), into six different past lives (Iverson,
spirit: “I am traveling [in the space], I was told 1976). The earliest recalled life was as ‘Livo-
[I lived on earth] but I left my body” (de nia,’ wife of Titus in Roman Britain during the
Rochas, 1911; p. 95). When Mme Roger is 3rd century in AD 286. The patient went on to
asked to take the form of a human body again recall lives in 1189, 1450, the early 16th cen-
she claimed her name was “Madeleine Beaulieu tury, 1702, and the early 20th century. In 1189
and it is 1724.” Later, she recalled another past she was Rebecca, a wife of a wealthy Jewish
life in which she was now “48” and her name is moneylender: it is “the Christian year of 1189”
“Philibert.” She explained that Louis XIV (Iverson, 1976; p. 33), and “good King Henry
(1638 –1715) is ruling the country (p. 98). has died and King Richard is away, in the
We also found more recent accounts of epi- crusades” (p. 40).
sodic memories of past lives, again in hypnosis. Also in the 1970s, American clinical psychol-
Morey Bernstein was an amateur hypnotist who ogist Edith Fiore (1978) described eight cases of
treated a patient called Virginia. Bernstein patients who recovered memories of previous
FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980 161

lives under hypnotic age regression. For exam- be calm about, and he recounted how that had
ple, the first case depicted in the book, Becky affected him. Later, he regressed back even
(age 22), recovered memories of her past life as further and reexperienced one of his past re-
girl several centuries ago. incarnations: “I’m in a cell. Like a jail cell.
I’m a prisoner” (p. 110). Chuck reported it
Dr Fiore: “What is your name?”
was the 1940s, and that he was on death row
Becky: “Elaine?” in prison for murdering his infant. He remem-
bered: “they’re strapping me to a chair. It’s
Dr Fiore: “How old are you?” the electric chair. A sudden burst like white
Becky: “Fifteen.” lights, but in my head. My body is bouncing
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in the chair . . . And it stops.” As if this


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Dr Fiore: “On the count of three the date memory was not enough for the child patient,
will occur to you . . . What come he then remembered hearing: “‘He’s an active
to your mind?” one he’s not dead yet.’” Then, the second
Becky: “1664.” (Fiore, 1978; p. 30) shock: “There’s another burst in my head.
They turned it on again. I’m dead” (p. 110).
Becky, still experiencing hypnosis, de- Past life memories have been recovered not
scribed Elaine’s death when she was raped only with hypnosis but also with LSD ther-
and stabbed by three men: “[I feel] cold . . . I apy. For example, Grof (1980) describes a
feel like I’m watching . . . I think I’m dead. [I patient, Tanya, a 34-year-old teacher at the
see] the three men run away.” (pp. 42– 43). time, remembering a previous incarnation as a
Even more bizarre, she identified one of rap- young girl from New England who was ac-
ists as a past incarnation of Becky’s own cused of witchcraft (the year is not known,
father. The therapist, Fiore, asked the father but it may be the witch trials of the late
to join his daughter during a therapy session. 1600s). She remembered how the villagers
Becky’s father seemed to accept the idea that had taken her to the birch-grove and drowned
in a previous incarnation he had murdered a her. She recognized among her attackers, two
previous incarnation of his daughter and men from Tanya’s present life: past incarna-
could not help but apologize for what he had tions of her father and husband (p. 288). The
done to his daughter. latter pattern of incorporating present day
Around the same period as Fiore, American faces into impossible memories of past lives
past life therapist Dr. Morris Netherton (1978) demonstrates how people can confabulate and
described similar case studies. One patient, reconstruct memories from both real and
Carl, recalled a past life in “primitive times,” in imagined sources.
a village in South America or Africa. In this Evidence of episodic recall of past lives is
past life, he slept with the wife of one of his strong evidence of memory distortion because
rivals, and when the husband came back to the there is little or no credible evidence for ac-
hut: “he hurls that spear and he’s got me, right tual occurrences of past lives. Although Ste-
there in the gut.” Still conscious after he was hit venson (1994), in an otherwise skeptical arti-
by the spear, his assailant continued the attack: cle, claimed that there may be very rare cases
“Now he’s reaching down and he’s cutting it that offer some evidence of past lives, meth-
off. My penis . . . I can’t feel it” (Netherton, odologies of studies supportive of past lives
1978; p. 58). have met with considerable criticism (see
Unfortunately, Netherton also treated an Mills & Lynn, 2000). Similarly strong evi-
11-year-old child, Chuck, who recovered dence of false memories is associated with
memories of his in utero life as well as hor- another type of impossible memory: abduc-
rific memories of a previous life: “I’m a very tion by space aliens.
little baby. I’m not really a baby yet. I’m
inside still. I’m three months along.” (Neth- Section 6: Memories of Alien Abduction
erton, 1978; p. 108). Chuck remembered,
while still in his mother’s womb, hearing Reports of space alien abduction are a fasci-
when the pregnancy was revealed. He heard nating demonstration of the distorting power of
the grandmother say that there is nothing to hypnosis, imagination, and suggestion on mem-
162 PATIHIS AND YOUNES BURTON

ory. A number of early precedents of reports of Section 7: Therapist Acknowledged False


alien encounters not involving therapy or hyp- Memories
nosis do not match our criteria for inclusion
(e.g., Swedenborg, 1758; Vilas-Boas in 1957, Perhaps the most surprising evidence we ob-
see Denzler, 2003). In addition, Flournoy tained were cases in which the therapists them-
(1899/2007), as briefly mentioned in the previ- selves admitted to creating false memories in
ous section, did report a woman who appeared their clients. We say surprising because we
to be in a trance-like state remembering a rein- found a number of cases that seem to have been
carnation as an entity on the planet Mars. This forgotten by many and predate the purportedly
experience of inhabiting a Martian was accom- recent idea that distorting memory could facil-
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panied by talk that the woman construed as a itate treatment (e.g., Nader, Hardt, & Lanius,
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Martian language. Flournoy himself suspected 2013). The therapists describe how they inten-
the Mars experience was the product of imagi- tionally modified their patients’ memory, some-
nation and expressed skepticism regarding this times claiming that it was beneficial and for
phenomenon, albeit not complete skepticism curative purposes, and at other times demon-
(see also Hyslop, 1900). This report did not strating the dangers of suggestion.
involve a memory of a physical encounter with The earliest account we found of a false
aliens, although it was an interesting precedent. memory that a therapist acknowledged dates to
American author John Fuller described one the 1880’s. Hippolyte Bernheim was a French
of the earliest reports of a physical (as opposed physician who described cases from the early
to psychical) alien abduction. In Fuller’s (1966) 1880s that involved the concept of ‘retroactive
story a couple remembered, after months of hallucinations’ (Bernheim, 1884, 1889). As we
hypnotherapy, their trip into a spaceship in decoded this old terminology, it became clear
which they were medically examined by strange he was talking about remembering false mem-
creatures from outer space. In 1961 Betty and ories (‘hallucinations’) about the past, in the
Barney Hill were driving home from vacation
present (i.e., ‘retroactive’). During hypnosis,
when they noticed a strange light in the sky.
Bernheim (original French: 1884; English trans-
According to Barney, the light was moving in a
lation: 1889) suggested to his patient Marie that
strange and unconventional way. When they
she had witnessed an old bachelor rape a young
arrived home, the couple was surprised to see
they were two hours late on their schedule; time girl. Marie is told she could see the little girl
was missing, which they could not explain. struggle and bleed. At the end of the hypnotic
Betty underwent seven months of therapy be- session, Bernheim added that “it is not a dream;
fore she recovered episodic memories of the it is not a vision I have given you during your
aliens’ facial features: “eyes continued around hypnotic sleep; it is the truth itself; and if in-
the side of the heads and had two slits that quiry is made into this crime later on, you will
represented the nostrils” (Fuller, 1966, p. 305). tell the truth.” (Bernheim, 1889, p. 165). A
She remembered being on an examination table friend of Bernheim’s questioned Marie three
when they “put a needle into [her] navel” as part days later. She gave him a perfect recollection
of a pregnancy test, and skin samples were also of the alleged event; the name of the rapist and
collected (p. 195). Fuller’s work perhaps was a his victim, as well as the date, time, and place of
precedent that inspired abduction memories af- the crime. Bernheim, in an attempt to test Ma-
ter 1980; for example, those reported by Har- rie’s confidence in her testimony, asked her if it
vard psychiatrist John Mack and others (Mack was not perhaps a “vision like those [he] was in
& Mack, 1994; see also Clancy, 2005). the habit of giving her during her sleep” (Bern-
Impossible memories are one way to confirm heim, 1889, p. 165; original French in Bern-
that the episodic recall was inaccurate, but an- heim, 1884, p. 12), but Marie remained adamant
other way is when the therapist or experimenter of the veracity of the story. She even agreed to
deliberately manipulates memory and knows testify at a trial, under oath. Bernheim wrote
that the implanted event did not happen. In the that he later used hypnosis to successfully re-
next section, we discuss the relatively strong move the implanted memories. Interestingly,
evidence in which therapists acknowledged like modern false memory researchers, he urged
memory distortion. caution in the use of suggestion by magistrates
FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980 163

and warned of false evidence given by children search of the 1990s, Hull (1930) and Young
in court (Bernheim, 1889, pp. 176 –177). (1927, 1931) had doubts regarding some of the
In contrast to implantation of false traumatic elaborate claims of hypnosis and described con-
memories as described by Bernheim, French trolled research that revealed a more sober as-
psychotherapist Pierre Janet (1894) described a sessment of the power of hypnosis. In particu-
case of erasing a true memory. Janet described lar, Hull and Young doubted the ability of
a client, Justine, who had been obsessed with an hypnosis to enhance memory, although they
intense fear of contracting cholera. They traced seldom mentioned or researched false memories
the phobia back to an incident 20 years earlier directly.
when she saw two corpses of people who had Even more bizarre than the implantation of
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died from the disease. Janet wrote: past events are constructed “memories” of the
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future. Psychiatrists Rubenstein and Newman


I transformed the appearance of the cadavers, and
above all I spent several sessions dressing them. The
(1954) published a report in Science describ-
hallucination of a garment, and then another, was fairly ing how they had hypnotically “progressed” a
successful, and finally the main body seemed saddled group of five subjects to a future time 10
with the costume of a Chinese general that Justine had years in the future. They described, in detail,
seen at the exhibition. The success was mostly full their activities at the future given date. They
when I managed to get the Chinese general to stand up
and walk, it was not terrifying anymore but rather noted that the participants “fantasied a future
comical. (Janet, 1894, p. 128) as actually here and now.” They suggested
that many descriptions of hypnotic regression
Although not as clear as the Bernheim and also consist of “confabulations and simulated
Janet examples, we also found circumstantial behavior” (Rubenstein & Newman, 1954; p.
evidence of distortion during the hypnosis done 473). They were skeptical of these techniques
by French neurologist Jean-Martin Charcot. and challenged the validity of hypnotic re-
Charcot (1887) describes how a patient seemed gression. Nevertheless, perhaps they were un-
to reconstruct a memory of a traumatic accident: aware of Bernheim (1884) and Janet’s (1894)
“of the accident itself he does not remember work discussed above, because Rubenstein
much, despite what he says, and it is likely that and Newman (1954) go on to make the rather
everything he says, he dreamed it or uncon- unfortunate remark that their skepticism
sciously constructed it, exaggerating everything about hypnotic regression probably does “not
he heard or was told” (p. 456; our translation). apply to the reenactment of traumatic past
Similarly, one of Charcot’s patients suffered experiences” (p. 473).
amnesia after hurting his head, and Charcot As described, there are numerous examples
writes he “recovered memory of the incident before 1980 when therapists purposely induced
after he heard people around him talking about false memories. They did so to either demon-
it” (pp. 442– 443; our translation). Like Bern- strate the malleability of memory or to demon-
heim and Janet, Charcot acknowledged memory strate the treatment potential for such tech-
construction in patients, but it is less clear what niques. If we take these authors at their word,
the events he referred to are and to what degree and in light of recent false memory research we
hypnosis induced the distortion. have good reason to do so, this presents strong
There are interesting parallels between the evidence that false memories occurred in psy-
more recent memory wars of the 1990s and the chotherapy before the more recent controversy.
time period of Bernheim, Janet, and Charcot,
such as the legal implications of memory dis- Discussion
tortions. Indeed Laurence and Perry (1988) dis-
cussed some of these legal implications even The standard narrative of false memories in
before the proliferation of legal cases of the psychotherapy involves a story of how the phe-
1990s related to the recovery of repressed mem- nomenon arose in the 1980s and caused a contro-
ories. For example, Liégeois (1884), a fellow versy in the 1990s. Here, we have documented
member of the Nancy school of hypnosis with many earlier examples of autobiographical mem-
Charcot, wrote about the legal implication of ories implanted in therapy. The evidence we pre-
hypnotic suggestion. Similarly, in what appears sented ranged from 1884 to 1980 and ranged in
to be a parallel to the skepticism-inspired re- strength from infantile memories to physically
164 PATIHIS AND YOUNES BURTON

impossible memories. We showed that some ther- (1987) concluded that the technique does not
apists openly acknowledged the implanting of en- reliably recover real memories of childhood,
tire autobiographical events, whereas others im- and that behavior of patients when age re-
planted memories without knowing that they were gressed is not accurately childlike. In research
most likely false. relevant to past life memories, Spanos, Menary,
The strongest evidence for false memories Gabora, DuBreuil, and Dewhirst (1991) showed
earlier in history, paradoxically, may come that past life memories can be created in the
from sources that before the advent of recent laboratory with hypnotic procedures and that
false memory research we might have deemed these memories can be manipulated by altering
unreliable. That is, before 1980, some skeptics participants’ expectations regarding past life ex-
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may have thought that reports of episodic mem- periences. Implanting false memories of alien
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ories of the womb, past lives, alien abduction, abduction might be considered unethical in a
and bizarre satanic rituals, constituted com- laboratory study, but Clancy, McNally,
pletely unreliable evidence because the authors Schacter, Lenzenweger, and Pitman (2002)
were either lying or deluded. However, in light were able to show that participants who claimed
of the last three decades of false memory re- to have been abducted by aliens were more
search, especially the creation of autobiograph- susceptible to false memories of words that
ical false memories using techniques similar to were not actually presented in the lists of se-
those used in therapy (hypnosis: e.g., Laurence mantically related words they had seen.
& Perry, 1983; guided imagery: e.g., Garry et False memory research over the last few de-
al., 1996; suggestion: e.g., Loftus & Pickrell, cades has also shown that diverse samples of
1995), we argue that many or most of the cases people, and indeed animals, are vulnerable to
discussed in this article are not evidence of memory distortion. More specifically, the pli-
deliberate deception, but evidence of memory ability of memory has been demonstrated in
distortion. individuals with very good cognitive ability,
Recent research has shown that it is possible such as young adults at top universities (e.g.,
to instantiate false memories in the laboratory. Goff & Roediger, 1998) as well as in people
Some of these studies use or model some of the with superior autobiographical memory (Patihis
techniques and target the types of memories et al., 2013). Importantly, individual differences
described earlier in this article. For example, measures, including personality types, do not
Spanos, Burgess, Burgess, Samuels, and Blois predict memory distortions very strongly (e.g.,
(1999) demonstrated that suggestion could lead Zhu et al., 2010), which further reinforces the
to false memories of infancy. Specifically, fol- idea that false memory susceptibility is roughly
lowing suggestion, some participants reported evenly distributed throughout the population,
remembering a colored mobile in the first few implying that it may originate from a fundamen-
days after birth, and some reported “body mem- tal aspect of cognition. This speculation is rein-
ories” in the form of itching around the umbi- forced by research in mice suggestive of false
licus. Such memory distortion was found fol- memories (e.g., Ramirez et al., 2013) and also
lowing both hypnosis and nonhypnotic by memory reconsolidation research (e.g., Na-
suggestion. Likewise, Malinoski and Lynn der, Schafe, & Le Doux, 2000). In addition, a
(1999) used imagination and suggestive tech- number of legal cases have also suggested that
niques in a series of interviews that resulted in that some memories, even though genuinely and
ever-earlier reports of their first memories. Be- confidently believed in, are nonetheless false
fore the interviews, the mean age of first mem- (e.g., see Eberle & Eberle, 1993; Johnston,
ories was 3.7 years, and afterward it had de- 1988; Loftus & Ketcham, 1994; Montoya,
creased to 1.6 years, with 33% of participants 1995). Recently acquired empirical findings, ac-
reporting memories before the first year of life. cumulated over the past 20 years or so, there-
In other research relevant to our article, Lau- fore shine new light on false memory produc-
rence and Perry (1983) demonstrated that hyp- tion before 1980.
notic suggestion during an age regression exer- With respect to the writings before 1980, it is
cise could create false remembrances of striking how theory about memory seemed to
awakening to a loud noise. Indeed, in a review blind practitioners and clients to the obvious
of hypnotic age regression research, Nash fact that they were creating false memories. It
FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980 165

was as if they were part of a failing scientific planted the seeds for the controversies regarding
paradigm (cf. Kuhn, 1962) in which they had to memory that erupted in the 1980s and 1990s.
work ever harder to fit the data within their Given our findings, we contend that the widely
theoretical framework. For example, the theory held, yet limited historical narrative of false
of cellular memory probably contributed to memories in psychotherapy can be expanded.
false memories of being in the womb (e.g., Rather than a story of how false memories
Hubbard, 1950), the theory of active repression emerged in the 1980s and 1990s, we can now
of trauma appeared to be a major culprit in better appreciate the historical antecedents of
creating false memories of severe trauma (e.g., false memories and iatrogenic methods in hyp-
Freud, 1896/1953), and the theory that con- nosis and psychotherapy. In demonstrating rel-
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sciousness could transcend death no doubt con- atively clear evidence of false memories in ther-
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tributed to recall of past lives (e.g., Netherton, apies before the 1980s, it is now a tenuous
1978; cf. Spanos et al., 1991). In many such argument to maintain that false memory pro-
theories the lack of falsifiability of core con- duction in therapy is a politically motivated
structs is an issue, and this is perhaps why myth propounded by a number of individuals on
advocates of such theories have not conducted one side of the 1990s memory wars. The his-
research that actively seeks disconfirming evi- torical roots of debates regarding false memory
dence (see Popper, 1957). formation might be useful to disseminate to the
The evidence we have presented has some general public, who might encounter highly
noteworthy limitations. Findings based on an- critical information about false memory re-
ecdotes and case studies are not as scientifically search on the Internet. The long history of mem-
valid or definitive as repeatable findings derived ory distortion in therapy might also be useful to
from controlled laboratory experiments. Never- share with clinical psychologists in training
theless, our reliance on case studies to some who may benefit from knowing what has gone
extent was unavoidable. That is, we sought ev- askew in the past to prevent the repetition of
idence of autobiographical memory distortion such mistakes. Historically, clinical psychology
in psychotherapies and separately considered PhDs have had license to devise their own ther-
research that yielded ample and convincing ev- apies or modify existing ones, and this is still
idence of memory distortion. Moreover, we true today. For this reason, new clinicians may
may have failed to identify one or more poten- continue to engage in potentially harmful and
tially relevant sources published during the past suggestive therapies that distort memory; our
200 years. We also were unable to include ther- hope is that this article will help to prevent or
apy-induced false memories of plausible events mitigate that practice.
that could have occurred but did not actually
occur. Accordingly, our account probably un-
derestimates the true nature and prevalence of References
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