Repressed Memories

▪ 1995

by Michael D. Yapko

      In 1994 the mental health profession found itself deeply divided over an approach to psychotherapy known as "repressed memory therapy," or RMT. RMT relies on so-called memory-recovery techniques to help a patient "remember" or "recover" episodes, usually of sexual abuse, from childhood—episodes that presumably have been "forgotten." The abuse is assumed to be an underlying cause of the patient's current symptoms.

      RMT is based on the theory that in order to cope with the trauma of being abused, the victim employed a psychological defense known as dissociation. Dissociation involves "splitting off" awareness so that the conscious mind is "elsewhere" when the abuse takes place. The result is repression, a self-protective memory loss, or amnesia. Despite the fact that the painful experiences are consciously forgotten, the repressed material can still cause severe symptoms; often these symptoms have no clear cause. The therapist's role in RMT is to help the patient recover the memories. Presumably, once the memories have been brought into awareness, the survivor's present problems can be effectively treated.

      The professional controversy over RMT centres on questions such as: Why and under what conditions does an individual repress traumatic memories? Can one completely forget repeated episodes of childhood sexual abuse? Might the memories that are recovered have been "manufactured" to accommodate the expectations and suggestions of the therapist or to account for otherwise puzzling symptoms? Is it possible for a therapist to lead a patient to believe that he or she was sexually abused when no such event actually occurred? And perhaps most important, how should therapists conduct themselves when the answers to these questions remain unclear?

      Mental health professionals generally agree that sexual abuse of children has been and is a widespread problem. They recognize that historically survivors of such abuse have been discounted owing to a "cultural denial" that has minimized both the scope and the seriousness of the offense. They know that creating a climate in which survivors can come forward, disclose what happened to them, and be believed is vital to their eventual recovery. Beyond this, however, opinions diverge.

      On one side are those who believe that dissociation and repression are common responses to sexual abuse in childhood and that victims generally can be readily identifiable from a known list of symptoms. In their view, treatment should first lift the veil of repression through techniques such as hypnosis or "guided imagery." The therapist then must help the patient deal with the painful memories. Proponents of RMT are concerned that any disbelief in these assumptions on the part of therapists makes it more difficult for sexual abuse survivors to disclose their problems and easier for perpetrators to evade responsibility for their terrible deeds. They reject the notion that detailed traumatic memories can arise merely on the basis of suggestion, contending that such memories need to be acknowledged as true before treatment can succeed.

      On the other side of the controversy are those who view dissociation and repression as uncommon responses. They have grave doubts that anyone can suffer repeated trauma over a long period of time and repress all the memories, only to recover them many years or even many decades later under the influence of therapy (or some other suggestive source, such as a book or talk show). RMT opponents do not believe that victims can be identified on the basis of a "symptom checklist." Furthermore, they hold that it is unsound to hypothesize a history of abuse on the basis of symptoms that might be explained by other means. They recognize that some people may be particularly vulnerable in certain contexts—for example, psychotherapy—and thus may accept "evidence" that has no basis in fact. When therapists conclude that a patient has been sexually abused, they may lead that patient, intentionally or unintentionally, to reach the same conclusion. Consequently, appropriate treatment for that patient is delayed or even prevented. And finally, RMT opponents are concerned that innocent people will be falsely accused of perpetrating abuse, and their lives and families will be destroyed as a result.

      Professionals on both sides of this controversy argue their points vehemently and intelligently, and both groups are motivated by a desire to help "victims" or potential victims.

      In order to accommodate the theory of repressed memories, many U.S. states have passed laws allowing a "delayed discovery" to serve as the basis for civil suits. Otherwise, the statute of limitations in these cases would have expired. By the end of 1994, about 500 legal actions had been initiated—most often by a daughter against an allegedly abusive parent. Within the past two years, several cases have been highly publicized, bringing the RMT controversy before the public.

      One such case involved Gary Ramona, a successful northern California winery executive, whose daughter Holly had sought psychotherapy for depression and bulimia (a severe eating disorder) when she was a college student. During her treatment in 1989-90, she began to recall scenes of sexual abuse from her childhood and came to believe they involved her father. In the process of therapy, she was given sodium amytal, the so-called truth serum, in an attempt to validate her conclusion that her father had abused her. While under the influence of the drug, she recounted specific instances of abuse by her father.

      When Ramona was publicly accused of child sexual abuse, he vehemently denied it. Nonetheless, he lost his job, his wife left him, and his two other daughters cut off all contact with him. His reputation, family, and career thus ruined, Ramona filed an $8 million malpractice suit against Holly's former therapists and the medical centre at which they worked. He claimed they had planted inaccurate and damaging information in his daughter's mind and had used questionable techniques to do so. On May 13, 1994, the jury in the Napa county superior court where the case was tried awarded a judgment of $500,000 to Gary Ramona. The judgment was not based on the truth or falsity of Holly's memories but on how the memories were obtained. The jury believed the therapists had not conducted themselves appropriately in Holly's treatment.

      This case was significant because it was the first repressed-memory case in the United States in which a third party was awarded damages. Normally, if a therapist is sued, it is by a patient. Previous "standard-of-care" cases had considered only the therapist's responsibility to his or her patients, not to the patients' relatives. Another interesting aspect of the Ramona case was that the patient, Holly, testified on behalf of her therapists and continued to maintain that the abuse took place even after the court's decision.

      In another widely publicized case, 34-year-old Stephen Cook of Philadelphia filed a $10 million suit against Joseph Cardinal Bernardin of Chicago, claiming Bernardin had sexually abused him nearly two decades earlier when Cook was a seminary student. Cook had also accused another clergyman at the school of having molested him. Cook's memories of abuse by Bernardin came later and were obtained under hypnosis.

      The cardinal quickly and convincingly denied the accusations, bringing Cook's credibility into question. Cook then consulted a psychologist to evaluate his "memories" and determine whether he might have been influenced by the hypnotist. Subsequently, Cook acknowledged publicly that his memories were "unreliable," and in early 1994 he withdrew his allegations against Bernardin. Cook's accusation and subsequent retraction raised many doubts in the public's mind about the validity of RMT. (Cook's case against the other priest was later settled out of court.)

      In one of the most bizarre cases involving repressed memories, Paul Ingram, a former Washington state deputy sheriff, was accused by one of his daughters of sexual abuse. The charge stemmed from a memory that surfaced at a church retreat, where the subject of sexual abuse was discussed. Another of Ingram's daughters, who was at the same retreat, then claimed she, too, had been sexually abused by her father. Ingram's law-enforcement colleagues encouraged him to confess because that would help him "remember" the acts he must be repressing.

      Although the daughters' allegations were improbable—expanding to include many of Ingram's fellow officers as accomplices and to involve satanic rituals and even human sacrifices (all charges for which no evidence was ever found)—the investigators in this case believed the abuses had occurred. They did not think such detailed stories could be entirely untrue. A deeply religious man, Ingram reasoned that his daughters would never make up such charges; despite having no such memories, he concluded that the accusations must be true. Believing that neither God nor his daughters would lead him to imagine unfounded guilt, Ingram confessed and went to prison. His intense religiosity led him to believe that any image he conjured up in his mind of having perpetrated abuse must have been placed there by God, thereby confirming his "guilt."

      Without objective corroborating evidence—such as a photograph or videotape—how can a real memory of child sexual abuse be distinguished from an illusory one? At present, no reliable method exists for distinguishing truth from fiction in RMT cases. Clearly, the issues are complex, and courts have been asked to rule even in the absence of hard data. In 1990, for example, in the case in California of 30-year-old Eileen Franklin-Lipsker's recovered memories, the jury convicted her father, George Franklin, in the 1969 murder of one of her childhood friends after Franklin-Lipsker's testimony and that of child psychiatrist Lenore Terr convinced the jury beyond a reasonable doubt that Franklin was guilty. He was convicted of first-degree murder and sentenced to life in prison.

      As pressure increases from within the field to approach these sensitive cases with extreme caution, undoubtedly more careful research will be conducted. And as legal rulings shape public perception and further define professional responsibilities, the intensity of the RMT controversy is likely to diminish. In the meantime, therapists must, as always, honour the Hippocratic oath: "Primum non nocere" ("Above all do no harm").

Michael D. Yapko is a clinical psychologist in private practice in Solana Beach, Calif. He is the author of Suggestions of Abuse: True and False Memories of Childhood Sexual Abuse and Essentials of Hypnosis.

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