FMSF NEWSLETTER ARCHIVE - May 1, 1997 - Vol. 6, No. 5, HTML version

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ISSN #1069-0484.           Copyright (c) 1997  by  the  FMS Foundation
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  FMS News
      Focus on Science
        Legal Corner
          Book Reviews
            From Our Readers
              Bulletin Board

Dear Friends,

  Do "hit and run" accusations, "isolation" and "cutting-off" from
family and friends constitute legitimate psychological treatments?
That is the question that many families have asked the Foundation, but
it is more appropriate to ask that question of professionals and
professional organizations.
  "Isolation" is old stuff in psychiatry. In _A History of Psychiatry_
Shorter reminds us that in 1817, Esquirol recommended that "removal
from family and friends would contribute greatly to diverting the
patient from the previously unhealthy passions that had ruled his or
her life." (p. 13) Shorter writes that "The notion of isolating asylum
patients from friends and family was also very familiar. Historically,
these are techniques that each generation of psychiatrists invents for
itself."(p. 131)
  "Hit and run" accusations, "isolation" and "cutting-off" seem to
have become therapy practices accepted by too many clinicians in the
1990s. They were suggested by Bass and Davis in the book most widely
recommended by therapists, The Courage to Heal (1988), a book endorsed
by Judith Herman, M.D. (Guide to Self-Help Books, 1993).

  "The initial confrontation is not the time to discuss the issues, to
  listen to your abuser's side of the story, or to wait around to deal
  with everyone's reactions. Go in, say what you need to say, and get
  out. Make it quick. If you want a dialogue, do it another time."
  (p. 139)

  John Briere, Ph.D. (Therapy for Adults Molested as Children, 1989)
noted that psychological surgery or a "parentectomy" may be warranted
when the "nonoffending" parent directly or consciously defends the
molester and negates the survivor.
  Renee Fredrickson in Repressed Memories: A journey to recovery from
sexual abuse, (1992) recommends:

  "Avoid being tentative about your repressed memories. Do not just
  tell them; express them as truth. If months or years down the road,
  you find you are mistaken about details, you can always apologize
  and set the record straight. You cannot wait until you are doubt-
  free to disclose to your family. This may never happen." (p. 203)

  The Canadian Psychiatric Association has put itself on record as to
the dangers of the kinds of confrontations that have been a component
of recovered memory therapy, but no professional organization has yet
addressed the practice of cutting-off and isolation. The concern of
families is that cutting off and isolation are the very same practices
used by cults to control information and to prevent exposure to
alternative ideas.
  The current acceptance of "cutting-off" appears to be a carry-over
from the 1940s when mothers were thought to be the cause of
schizophrenia, autism and homosexuality. The term Schizophreno-genic
mother was coined in 1948, the heyday of explanations favoring
child-rearing attitudes as the central cause of schizophrenia.
Because the mother was considered to have caused the problem,
therapists who held this view removed the patient from the family, and
to undo the damage, the therapist would reparent the patient. This
belief kept a strong hold on a segment of the psychiatric community
through the 50s and 60s until the genetic bases of psychiatric
disorders began to be understood. It still continues in some therapy
  Untold thousands of mothers suffered needlessly because of the
misguided idea of schizophreno-genic mother, just as untold thousands
of mothers and fathers are suffering needlessly now because of this
recycled belief. Families should ask the professional organizations 
to address this question: Do "hit and run" accusations, "cutting-off"
and "isolation" from family and friends constitute legitimate
psychological treatment? What does the evidence show? We suggest you

  Harold Eist, M.D., President
  American Psychiatric Association
  1400 K Street NW
  Washington, DC  20005

|                             CORRECTION                             |
| In the April newsletter on page 2 under "Our Critics" the          |
| reference to the preface of an e-mail solicitation of protest      |
| letters was ambiguous. The author of the preface was "martin" and  |
| the subject reference was "Urgent Action Call re: Abusers Lobby."  |
| The sender was crossposted on the mailing list. Ms. |
| Sherry Quirk, the president and legal counsel for ACAA, was not    |
| the author of the preface and we apologize for any confusion.      |

                           F M S    N E W S 
            Lawsuit Filed against Renee Fredrickson, Ph.D.
On April 4, 1997, a lawsuit was filed against Renee Fredrickson, a
St. Paul psychologist who became a best selling author and nationally
known speaker by claiming expertise in "repressed memories" of sexual
abuse and "recovered memory therapy." In the lawsuit, Renee
Fredrickson, Ph.D. was accused by a former client of using hypnosis,
misinformation and suggestion to implant horrifying false memories of
"ritual cult abuse." Through her books, audiotapes and seminars,
Fredrickson trained hundreds of other therapists in the controversial
methods of "memory recovery." Fredrickson was a founder of one of the
organizations that merged to become the American Coalition of Abuse
Awareness (ACAA). The plaintiff's lawyer is R. Christopher Barden,
Ph.D., J.D. See "Legal Corner" of this issue for more details.
                  First Amendment/Blacklist Project
On March 12, 1997, there was a press conference at the Motion Picture
Academy in Los Angeles to launch a project to commemorate the victims
of McCarthyism and the blacklist. In addition to some of the famous
blacklisted writers, Carol Tavris was asked to speak. Among her words:

  "The second lesson is that the blacklist wasn't unique at all. It
  has recurred throughout our history-never in the same form, but
  always part of the same impulse. McCarthyism was what sociologists
  call a moral panic-a contagion that allows people to displace their
  fears and anxieties onto the social devils of the moment. In various
  times our devils have been witches, Communists, foreigners,
  pedophiles, homosexuals, prostitutes, and of course rock and roll
  musicians. At this very moment, thousands of parents have had their
  lives ruined, and nearly a hundred daycare workers are in jail,
  because of preposterous and wholly unconfirmed charges of sex crimes
  against children, such as satanic ritual abuse. During McCarthyism,
  teachers feared for their jobs if they belonged to a left-wing
  group.Today teachers fear for their jobs if they hug a crying
  child. As in all moral panics, an accusation is enough to destroy a
  person's life. Hysteria trumps evidence."

For more information about the First Amendment/Blacklist Project,
write to 9538 Brighton Way, Suite 332, Beverly Hills, CA 90210.
                            Memory Systems
        and the Psychoanalytic Retrieval of Memories of Trauma
                    C. Brooks Brenneis, JAPA 44/4
This article about flaws in the concept of traumatic memory notes that
the concept of a special traumatic memory includes the notion that an
overwhelming psychic experience generates a defensively altered state
of consciousness (specifically dissociation), "which encodes memory in
unassimilated visual, somatic, and behavioral, rather than linguistic
modes. Analytic reevocation and interpretation of the original altered
states of consciousness then permits the transformation of 'early'
traumatic memory into 'later' explicit memory." He believes that the
flaws in this theory when extended to patients without explicit memory
of trauma are: "first, dissociation is a chameleonlike process,
perhaps as closely associated with suggestibility as with trauma;
second, state-dependent learning does not adequately account for the
absence of explicit memory and third, implicit memory does not map
onto explicit memory in any direct or simple fashion." He notes that
the "clinical application of current propositions about traumatic
memory to patients without explicit memory of trauma may warrant
considerable caution."
                    Sybil-The Making of a Disease:
                An Interview with Dr. Herbert Spiegel
    New York Review of Books, April 24, 1997 Mikkel Borch-Jacobsen
The diagnosis of Multiple Personality Disorder (MPD) was born with the
publication of Sybil in 1973. Although there were earlier books, such
as The Three Faces of Eve, it was Sybil that tied MPD to child abuse,
a notion that has become an essential feature of present-day MPD. MPD
was included in the DSM-III in 1980 due to the efforts of Putnam,
Braun, and Kluft.
  Dr. Herbert Spiegel said that he did not believe Sybil suffered from
MPD. He also said:

  "The therapists, with some exceptions, have become unconscious con
  artists. They are taking highly malleable, suggestible persons and
  molding them into acting out a thesis...I think in this respect that
  the MPD phenomenon of Sybil is an artifact that was created by Connie
  Wilbur...But I understand that the insurance companies are wising up
  and are cutting down on this. This may well be the end of the whole

When asked why he had not spoken out about this before now, Dr.
Spiegel replied, "Because I was never asked as you are now asking me."

                      F M S F    F E A T U R E S
                   Returner and Retractor Research
                              FMSF Staff
In the April newsletter, we presented data from the Family Survey
Update. We noted that 7% of the adult children of the families who
returned the survey had retracted and about 25% had "returned."
("Returners" is the term that we use to refer to children who have
returned to the family in some ways after a period of alienation and
accusations but who do not talk about what happened.) What do we know
about returners and retractors? How do families cope with the changed
situations? This month we include (1) the results of interviews with
nine families after their child had returned, (2) a summary of the
retractor research and (3) an article by Joseph deRivera, Ph.D. that
reports on some retractor research and its implications for returners.
  Prior to the Family Survey Update, we conducted a series of three
structured telephone interviews each with nine families over a time
span ranging from eight to fifteen months, starting when they first
notified us that their child seemed to be a returner. We hoped we
might gain some insights into the family dynamics that lead from
returning to retractions. The ages of the parents ranged from 56 to
84 and the accusers age ranged from 28 to 48 years old. One therapist
sent a letter to the parents explaining how she reached her diagnosis
of sexual abuse by using scores on Blume's "Incest Survivors After
Effects Checklist," Fredrickson's "Symptom Checklist for Repressed
Memories," and Whitfield's "Core Issues of a Person Raised in a
Dysfunctional Family." They seemed typical of FMS accusations and
  Most of these parents did not really know what brought about the
reconnection to family. One mentioned it happened when the accuser had
a baby. Another mentioned that her child returned on Mother's Day.
Another said that illness in the family accounted for the return to
the family. One person thought that her daughter returned because she
had changed therapists while another believed that her intervention on
behalf of the grandchildren was the reason.
  In each of three interviews parents were asked about the amount of
contact and the type of contact, and how that developed with time. In
three cases the reconnection was with just the mother. Contact
involved letters, phone calls and face-to-face meetings at family
gatherings.Topics for discussion included such things as grandkids,
daily life and baseball. The majority of parents indicated caution,
but they also seemed upbeat ("it gets better," "felt good," "distance
is closing"). In a few cases more negative statements were detected
("tired of the game," "felt the coolness," "feels superficial"). One
family did not want to have a third interview. Their daughter had
retracted and apologized and they just "wanted to put this behind
them." In the nine families involved in the course of the year one
family reported a retraction, two families indicated that
communication did not continue, and the rest of the families reported
C4J~that relationships seemed to be improving. None of the nine families
was seeing a professional for help with reconciliation.
  Although these data provide no clear guidelines for the hundreds of
families who are now struggling with the problem of how best to handle
family reconciliation, they indicate what occurred in a small sampling
of families with returners.

                          Retractor Survey:
Harold Lief, M.D. (FMSF Advisory Board Member) and Janet Fetkewicz
(FMSF staff) studied retractors to see if they could gain insights
into the processes that take place. The FMS Foundation has helped a
number of researchers make contact with retractors and a number of
studies are emerging that are listed in the references.
  Lief and Fetkewicz's first work involved obtaining basic profiles of
retractors that included demographics, therapy history and family
contexts. Their ground-breaking analyses of the comments of 40
retractors have informed everyone working in this new area. Lief and
Fetkewicz identified specific themes that seemed to be involved with
acquiring and later leaving false beliefs. Some of their findings have
appeared in the Journal of Psychiatry and Law in 1995 and others are
currently in review. Janet Fetkewicz and Toby Feld are currently
expanding on this work. Structured interviews with a much larger
population are in progress. Not only do they hope to gain greater
depth and detail, they want to identify specific groups for further
research. For example, the March FMSF Newsletter contained a short
notice of work about suicides and the MPD diagnosis. We will continue
to work with other researchers and publish information in as timely a
fashion as is possible.

                      Current Retractor Research
  deRivera, J (in press). The construction of false memory syndrome:
The experience of retractors. Psychological Inquiry.
  Lief, H.I and Fetkewicz, J.M. (1995). Retractors of false memories:
the evolution of pseudomemories.  Journal of Psychiatry and Law, 23,
  McElroy, S.L. and Keck, P.E., Jr. (1995). The formation of false
memories.  Psychiatric Annals, 25, 720-725.
  Nelson, E.L. and Simpson, P. (1994). First glimpse: an initial
examination of subjects who have rejected their visualizations as
false memories.  Issues in Child Abuse Accusations, 6, 123-133.

           First-Person Accounts by Retractors in Journals
  Gavigan, M. (1992). False memories of childhood sexual abuse: a
personal account.  Issues in Child Abuse Accusations, 4(4), 246-247.
  Hines, S.H. (in press). A retrospective tale of psychotherapy: An
incest dream.  Psychotherapy Bulletin.
  Pasley, L. (1994). Misplaced trust: a first-person account of how my
therapist created false memories.  Skeptic, 2(3), 62-67.

    |                       SPECIAL THANKS                       |
    |                                                            |
    |       We extend a very special "Thank you" to all of       |
    |      the people who help prepare the FMSF Newsletter.      |  
    |                                                            |
    |   EDITORIAL SUPPORT: Toby Feld, Allen Feld,                |
    |                           Howard Fishman, Peter Freyd      |
    |   RESEARCH: Merci Federici, Michele Gregg, Anita Lipton    |
    |   NOTICES and PRODUCTION: Danielle Taylor                  |
    |   COLUMNISTS: Katie Spanuello and                          |
    |       members of the FMSF Scientific Advisory Board        |
    |   LETTERS and INFORMATION: Our Readers                     |

                          UNDERSTANDING FMS
                  Joseph deRivera, Clark University

We know from the reports of retractors that many people have developed
false memory syndrome (FMS). Still, it is difficult for most of us to
understand how this might have happened. In this article we describe
three different ideas or models that may help explain how FMS could
happen: mind-control, self-narrative, and role-enactment. We then
describe a study in which we asked retractors if they felt that these
models described their own experiences. Following is an abbreviated
description of the three models:

The essential feature of mind-control is that a person's confidence is
undermined. Lacking confidence, a person then allows someone else, an
authority, to provide a story that accounts for the person's behavior.
Because the authority figure usually controls information, behavior,
thoughts and emotions, the patient's confidence is undermined.
Information control is achieved by actively discouraging contact with
people who think differently and by systematically distorting any
disconfirming evidence. Behavior control is achieved by telling the
person what to do and by requiring that the patient get approval for
personal decisions. Thought control is achieved by a particular use of
language. On the one hand, the language that is used overly simplifies
issues and makes the person feel special and part of a group that is
"good." On the other hand, the authority uses language that confuses
the person's sense of guilt and responsibility. The language promotes
a fear of what will happen if the patient leaves the authority figure.
Although a person may feel ashamed or guilty because of making a false
accusation, it is important for others to realize that in some sense
she or he was not really responsible for the accusations the authority
figure had the person make. (For further information see Steven
Hassan, Combating Cult Mind Control).

All people try to make sense of their lives by creating a story to
explain why they behave the way they do. When people are unhappy, they
may search for explanations from childhood in an effort to find an
acceptable story. Because there are many books and people that talk
about repressed memories, people may use their own imagination to
create a story about how they were abused based on some isolated
images and feelings. Gradually a person starts to make sense of
problems by assuming that a horrible trauma must have occurred. A
therapist may believe a patient's abuse story and help her to develop
it. A therapist may assume the patient repressed a memory and may even
become a coauthor of the story. In contrast with a mind-control model,
however, the patient retains control and acknowledges that she or he
was the author of the story. In this model, a therapist or well-
meaning others can lead a person to give credibility to his or her own
imagining. (See Ted Sarbin, A narrative approach to 'repressed
memories' in the Journal of Narrative and Personal History, 1994).

We all enact roles such as fathers or mothers, or teachers or
students, prisoners or guards, etc. Recently, our society has created
a new role, that of the "survivor" of abuse. Regardless of whether a
person chooses that role or is cast in it, his or her behavior fits
the expectancies of others. Survivors are expected to search for
traumatic memories and discover horrible things that happened. They
are rewarded when they play the role correctly and may be validated by
others. This role, like any other role, has certain advantages and
disadvantages. One of the advantages is that survivors of sexual abuse
are not expected to be perfect husbands, wives, or parents. They are,
however, expected to be justifiably afraid of, and angry at, those who
"abused" them. A person may be somewhat aware that she or he is
enacting a role or, like a good method actor, persons may almost
completely forget that they have been cast into a role. In this model,
a patient is not so much an author of a story (as in the narrative
model) or the subject of a therapist's story (as in mind-control
model), as they were actors in a drama that is being played out in our
society. (See, for example, The account of role enactment in a
simulated prison by Haney, C., Banks, C., & Zimbardo, P. in the
International Journal of Criminology and Penology, 1971).
  Do any of these ideas really apply to the development of FMS? We
asked people who had actually experienced FMS if they feel that any or
all of the ideas apply to their own experience?
  A 14-page questionnaire was mailed to 159 retractors asking people
to rate each idea (on a seven-point scale) as to the extent it was not
at all (1) or completely (7) applicable to their experience1. 56 (35%)
returned completed questionnaires.
  The table below shows the number of people who reported that an idea
fit their experience, as indicated by a rating of at least 5
("captures a lot of my experience").

  Number of Persons Endorsing Each Idea
    Idea 1  Mind-control    23
    Idea 2  Self-narrative  10
    Idea 3  Role-enactment   2
    Idea 1 and idea 2        1
    Idea 1 and idea 3        7
    Idea 2 and Idea 3        3
    All these Ideas          4
    None of the Ideas        6

  A majority of retractors endorsed the idea of mind-control and a
therapist's "undue influence" is a factor in at least 63% of the
sample. However, it is clear that mind-control is not the only factor
involved in these cases, and 15 cases are better explained by the
ideas of self-narrative or role-enactment2. Since no one theory can
account for all FMS cases, it is important for us to realize that
there are different ways FMS can develop, and different factors that
may be important in each individual case.
  It may be easier for families to cope with FMS cases that involve
mind-control or role-enactment. While there is little that can be done
until circumstances lead to a cessation of therapy, once the undue
influence is removed communication may sometimes be reestablished if
the family understands how the person was trapped in an impossible
  To the extent that a person's own imagination is involved in a
self-narrative, a family faces a difficult task because the accuser is
immersed in a narrative that may function to explain problematic
behavior, troublesome feelings, provide relief from self-blame, or
provide sympathy. Whether or not such a self-narrative will change
may depend a great deal on forces in the patient's situation that led
her to therapy in the first place. If the person is no longer immersed
in a group that encourages her to be a survivor, if the stresses that
led the person to therapy are reduced, and if the person becomes more
focused on current functioning rather than memories, she may be more
open to alternative explanations. Because information from their
families is so suspect by the accusers, it will likely be other
persons, articles, TV shows, etc. that will suggest the possibility
that at least some elements in the self-narrative may be incorrect.
Families are important to most people. To the extent there are
emotional bonds with family members it is likely that the accuser will
want to have a coherent narrative that she can share with them.
  Unless deliberate deceit is involved, it seems unwise for family
members to insist that a returner make an acknowledgement of error.
They may, however, begin to suggest alternative narratives that can
explain problematic behavior. Disagreements can simply be acknowledged
and communication can be reestablished. Until a person is able to
create a different narrative to explain her problems, it will be
difficult for her to fully relinquish the old narrative. A returner
probably needs time and space to acknowledge the harm that has
occurred. Sometimes within the context of the false narrative, a first
step is for the accuser to state that she or he has "forgiven" the
supposed perpetrator. To the falsely accused, it may seem ridiculous
to be "forgiven" for something that was not done. At the same time, we
have all made some mistakes and we probably all need some forgiveness.
The emotional connection afforded by the forgiveness may pave the way
for trust to be reestablished. It can be confusing and frightening to
one's identity to recreate a self-narrative. Gentle patience, time,
communication with other family members, or work with a good therapist
may help the person to get on with life, explore issues of trust and,
ultimately, create a more authentic self-narrative and even deeper
relationships with family members.

  (1) The first part consisted of 51 questions that asked about the
process of therapy and how false memories developed, and the third
part asked for background information and how the false memories were
relinquished. (These results will be presented in a separate paper.)
  (2) In fact, persons who experienced straight-forward mind-control
may find it easier to retract once circumstances have led them to
separate from their therapists. If so, our sample is skewed and there
may be a much greater percentage of FMS cases to whom the second (or
third) ideas apply.

  /                                                                \ 
  | "She has very self-destructive symptoms, but these began only  |
  | after she started therapy."                                    |
  |                                                      A Sister  |

                   F O C U S   O N   S C I E N C E

  This is the third in a 4-part series examining the question of
  whether childhood sexual abuse causes psychiatric disorders in
  adulthood. The series is not intended to "forgive" or exonerate the
  morally repugnant phenomenon of child sexual abuse in any way but
  simply to examine the methodology of scientific studies claiming
  that child sexual abuse causes adult psychiatric disorders. The
  remaining column in the series will appear in the next issue of 
  the newsletter.
               Don't Buy that Lawrence Welk Recording!
                      The Problem of Confounding
                         Harrison Pope, M.D.
In the previous two columns, we have shown how selection bias and
information bias seriously compromise virtually all retrospective
studies.  But let us suppose that our intrepid investigators of our
previous two columns, Drs. Harrison and James, have now received an
even larger research grant to do an even more refined study. They
obtain a huge community sample, and select individuals with eating
disorders and matched control subjects with careful attention to
minimize selection bias. Then they interview subjects in both groups
under blinded conditions to avoid any information bias introduced by
the investigator. Instances of sexual abuse in both the eating
disordered and control group are scored only if they are unequivocal
and meet rigorous diagnostic criteria of demonstrated reliability.
Further, let us suppose that the investigators are able to obtain
confirmatory evidence in some manner to show that the sexual abuse
actually did occur in the cases in which it is reported (this last
item is probably a somewhat unrealistic expectation, but let us grant
it for the purposes of argument). Let us suppose that, even with all
of these rigorous methods to control for bias, Drs. Harrison and James
still are able to show a statistically significant difference when
they compare the prevalence of sexual abuse in the subjects with
eating disorders and the control subjects. Can they now, at last,
conclude that childhood sexual abuse contributes to the etiology of
eating disorders?
  Unfortunately, they still cannot. We will now grant that they have
shown as association between childhood sexual abuse and eating
disorders. However, as we have stated earlier, the fact that there is
an association between A and B does not necessarily mean that A caused
B. In fact, logically, there are three alternative explanations for
the association as shown in the following figure:

                            1)      A -> B
                            2)      B -> A
                            3)   A <- C -> B

In examining this figure, let us assume that childhood sexual abuse is
"A" and adult psychiatric disorder is "B." The first possibility, as
the figure shows, is that A causes B. In this case, that would be the
possibility that childhood sexual abuse causes adult psychiatric
disorders. This of course in the hypothesis that we wish to test. But
to establish this possibility, we must first rule out two other
possibilities. First, we must consider the possibility that B causes A
(i.e., that psychiatric disorder somehow predisposes to sexual abuse),
and second, we must allow for the possibility that B and A do not
cause one another, but both are caused by a third factor, C (which is
often called a "confounding variable").
  Let us look at these alternative possibilities. First, consider the
possibility that B causes A. There are many examples of this type of
association in ordinary life and in clinical medicine. Suppose, for
example, that we interview 100 overweight subjects and ask them if
they have a history of having used artificial sweeteners in their
coffee at some time in the last year. We then pose the same question
to 100 thin subjects. We find a highly significant difference showing
a clear association between use of artificial sweeteners and being
overweight. Do we conclude, therefore, that artificial sweeteners
cause obesity? Clearly not. The true direction of causality is that B
causes A, namely that being overweight leads individuals to use
artificial sweeteners more frequently.
  More difficult and less trivial examples come from clinical
medicine. Thirty years ago, for example, a study found that
agricultural workers who were more physically active were less likely
to develop heart disease than sedentary agricultural workers [1].
Would it be correct to conclude, therefore, that being sedentary
contributes to the evolution of heart disease? No. We must allow for
the alternative possibility that workers who already had early
symptoms of incipient heart disease (e.g. chest pain on exertion)
would be more likely to choose sedentary agricultural jobs than their
counterparts who had no symptoms of evolving cardiac disease. In other
words, B may have led to A, rather than A to B.
  Another obvious example exists in the area of sexual abuse:
individuals with mental retardation are more likely to have
experiences sexual abuse than individuals of normal intelligence [2].
But clearly it would be illogical to conclude that childhood sexual
abuse causes mental retardation. Rather, mentally retarded individuals
are more at risk for victimization because they are less able to
defend themselves against abuse.
  But do these arguments extend to adult psychiatric disorders? Is it
reasonable to argue that bulimia nervosa or depressive illness, or
anxiety disorders, appearing in an individual at the age of 20, could
possibly have predisposed him or her to have been sexually abused at
the age of eight? This possibility is not as far fetched as it might
seem. Specifically, studies have shown that individuals with adult
psychiatric disorders have often experienced prodromal symptoms (in
other words, premonitory symptoms) of their disorders extending far
back into childhood. For example, adults who display panic disorder or
bulimia nervosa are more likely to have experienced fear of going to
school ("school phobia"), fear of being separated from their mothers
("separation anxiety") or bedwetting ("primary enuresis") in childhood
[3]. Similarly, individuals with eating disorders as adults often have
histories of depressive or anxiety disorders long prior to the onset
of the eating disorder4. Therefore, it is possible that some
individuals with eating disorders in Harrison and James' study may
have displayed a degree of depression or other psychological distress,
even years ago in childhood, that rendered them more vulnerable to
being preyed upon by potential abusers.
  Admittedly, this particular direction of causality might account for
only a small portion of the possible association between childhood
sexual abuse and adult psychiatric disorders. However, we still have
to rule out the last of the possibilities shown in the figure above,
namely that A and B are both caused by a confounding variable, C. The
issue of confounding is again a constant problem, both in ordinary
life and in clinical medicine. To begin with a simple example,
suppose that we were to study 100 residents of a nursing home and ask
them if they had ever purchased a Lawrence Welk recording. Lawrence
Welk was a famous performer many years ago, and his recording were
very popular in the 1930's and 40's. Therefore, we would likely find
that a high percentage of the nursing home residents reported that
they had bought at least one such a recording at some time. If we then
obtained a comparison group from the community at large, we would
undoubtedly find that a far smaller percentage of our comparison
subjects had made such a purchase. In fact, some of them would
probably report that they had not even have heard of Lawrence
Welk. Does it follow from our findings that buying a Lawrence Welk
recording will cause you to end up in a nursing home? Should we put
warning stickers on all Lawrence Welk recordings in record stores,
alerting potential purchasers of the risk? Clearly not. In fact, the
association between ownership of Lawrence Welk recordings and nursing
home residents is simply attributable to the confounding variable of
advanced age. In other words, age is the "C" in the figure above.
  Turning to medicine, the literature is filled with the corpses of
theories that failed to take into account the possibility of
confounding variables. Even elegant and expensive studies, involving
big teams of investigators and hundreds of thousands of dollars in
costs, have sometimes proved dead wrong when it was later discovered
that a confounding variable had created a mere illusion of
causality. Of many examples that could be cited, one was the finding
of an association between the use of inhaled nitrites (so-called
"poppers") and the development of AIDS [5]. In the early 1980's before
the human immunodeficiency virus (HIV) had been isolated, various
epidemiologic studies were conducted to assess what factors might
cause people to develop AIDS. It was found that homosexual men who
used "poppers" to get a "rush" during sexual activity were markedly
more likely to develop AIDS than homosexual men who had not used these
drugs. Some studies even conducted elaborate statistical tests, called
regression analysis (to be discussed in more detail next month), in an
attempt to rule out possible confounding variables. Nevertheless,
inhaled nitrites still emerged as a statistically significant factor,
and it was concluded that they might cause, or at least contribute to,
the development of AIDS.
  Now, of course, we know that nitrites do not cause AIDS, and that
the disease is instead caused simply by infection with a specific
virus, HIV. It turns out, in retrospect, that certain sexual practices
that predispose to HIV transmission (especially receptive anal
intercourse) are closely associated with use of "poppers." In other
words, the association between nitrite use and AIDS was a real one,
but it was not a causal association at all. Instead, the association
was caused by the presence of a confounding variable, namely specific
sexual practices.
  Returning, then, to the new hypothetical study by Drs. Harrison and
James, we see that an association between childhood sexual abuse and
adult psychiatric disorder, however rigorously proved, might not be a
causal association at all. it might simply be due to any of a number
of confounding variables. Individuals who have been sexually abused in
childhood are also likely to have been physically abused, neglected,
or subjected to all manner of other difficulties while growing up.
Even more importantly, there may have been a genetic loading in their
families for disorders such as alcohol dependence or manic-depressive
illness [6]. Relatives with alcoholism or manic episodes (the "high"
periods of manic-depressive illness), in turn, may be more likely to
abuse a child in the family. But that abuse victim already carries the
genetic predisposition to develop psychopathlogy, even if she were not
sexually abused. In other words, childhood sexual abuse and
psychopathology would be expected to "travel together" down the family
tree as a result of the confounding variable of genetics alone, even
if the sexual abuse did not itself cause psychiatric disorders.
  Data that support this speculation come from one recent study that
described 12 sexually abused women with bulimia nervosa [7]. This
study was one of the few in which the psychiatric diagnosis of the
perpetrator, as well as that of the victim, was assessed. Of the eight
women in this study found to have been abused by a biological
relative, six (75%) were abused by a family member diagnosed with
alcohol dependence, a major mood disorder (such as manic-depressive
illness), or both. Now, there is substantial evidence that alcoholism
and major mood disorders are more prevalent in the family trees of
individuals with bulimia nervosa than in the population at large,
raising the possibility that there is a genetic link among these
various disorders [8]. It is possible, therefore, that genetic factors
alone might account for the association of sexual abuse and bulimia
nervosa observed in this investigation, and that sexual abuse itself
had no role in causing the adult eating disorder at all.
  In summary, association does not prove causality. This is not a
difficult concept. It represents one of the most basic teachings of
"Psychology 101." And it is easy to illustrate, as shown by our
examples of the association between use of artificial sweeteners and
obesity, or purchase of a Lawrence Welk recording and nursing home
residence. Yet this elementary principle is ignored, or only barely
acknowledged, in many scientific studies of childhood sexual abuse. It
is even more rarely noted in popular reports of these studies in the
media. The lay reader, hearing the latest media report of a new "major
study" like that of Drs. Harrison and James, must be wary. A history
of childhood sexual abuse may well be associated with some adult
psychiatric disorders, but it is premature to jump from this finding
to an assumption of causality.
  [1]. McDonough, J.R., Hames, C.G., Stulb, S.C., & Garrison, G.E.,
Coronary heart disease among Negroes and whites in Evans County,
Georgia, J. Chron Dis 18: 443-458, 1965.
  [2]. Tharinger, D., Horton, C. B., & Millea, S. Sexual abuse and
exploitation of children and adults with mental retardation. Child
Abuse Negl 14: 301-312, 1990, and Stromsness, M. M. Sexually abused
women with mental retardation: Hidden victims, absent resources. Women
and Therapy 14: 139-152, 1993.
  [3]. Robinson, P. H. & Holden, N. L. Bulimia nervosa in the male.
Psychol Med. 16: 795-803, 1986, and Perugi, G., Deltito, J., Soriani,
A., Musetti, L, et al. Relationships between panic disorder and
separation anxiety with school phobia. Compr Psychiatry 29: 98-107,
  [4]. Hudson J. I., Pope, H. G., Jr., Yurgelun-Todd, D., Jonas,
J. M., & Frankenburg, F. R. A controlled study of lifetime prevalence
of affective and other psychiatric disorders in bulimic outpatients.
Am J. Psychiatry 144: 1283-1287, 1987, and Brewerton, T. D., Lydiard,
R. B., Herzog, D. B., Brotman, A.W., O'Neil, P. M., & Ballenger,
J. D. Comorbidity of axis I psychiatric disorders. J. Clin Psychiatry
56: 77-80, 1995.
  [5]. For a discussion of how an association was erroneously assumed
to be causal in this case, see Vandenbroucke, J. P., Pardoel, VPAM: An
autopsy of epidemiologic methods: the case of "poppers" in the early
epidemic of the acquired immunodeficiency syndrome. Am J. Epidemiol
129: 455-457, 1989.
  [6]. Cadoret, R. J. Genetics of alcoholism. In: Alcohol and the
Family: Research and Clinical Perspectives. Edited by R. L. Collins,
K. E. Leonard & J. S. Searles. New York, Guildford Press, (1990);
Tsuang, M. T. & Faraone, S. V. The Genetics of Mood Disorders. Johns
Hopkins University Press: Baltimore, (1990).
  [7]. Bulik, C. M., Sullivan, P. F. & Rorty, M. Childhood sexual
abuse in women with bulimia. J. Clin Psychiatry 50: 460-464, 1989.
  [8]. Hudson, J. I. & Pope, H. G., Jr. Affective spectrum disorder:
Does antidepressant response identify a family of disorders with a
common pathophysiology? Am J. Psychiatry 147: 552-564, 1990.

  This column appears as a chapter in the book, Psychology Astray:
  Fallacies in Studies of 'Repressed Memory' and Childhood Trauma, by
  Harrison G. Pope, Jr. M.D., Social Issues Resources Series, 1996.
  Copies of this book are now available and may be obtained by writing
  to Social Issues Resources Series at 1100 Holland Drive, Boca Raton,
  Florida, 33427, or by calling 1-800-232-7477.

/                                                                    \ 
| In the 12 months ending last June (1996), 182 adults, nearly all   |
| of them women, called or visited Nebraska sexual assault centers   |
| about childhood sexual abuse. That's more than the number of       |
| children treated for sexual assault at the same centers and nearly |
| as many as those seeking help after being assaulted as adults.     |
|                                                Omaha World-Herald, |
|  March 2, 1997 "Repressed Memories Illustrate Horror of Sex Abuse" |

                       L E G A L   C O R N E R
                 Illinois Appellate Court Holds that 
                 Therapist Owes a Duty to Third-Party
        Doe v. McKay, Illinois Appellate Court, 2nd District,
                  No. 2-96-0532, March 17, 1997 (1)
An Appellate Court in Illinois found that a therapist's duty to the
patient to use reasonable care in the treatment process is extended to
the parent. The case involved allegedly repressed memories of sexual
abuse where the parent was brought into the treatment process by the
defendant psychologist.
  From 1990 through October 1995, Jane Doe, the plaintiff's daughter,
underwent psychological treatment under the care of the defendants.
During the course of that treatment, she says she discovered repressed
memories of alleged sexual abuse by plaintiff. Plaintiff denied that
he ever abused his daughter. During three joint sessions that included
the plaintiff, Jane Doe, at the direction of McKay, accused her father
of sexual abuse. McKay allegedly repeatedly suggested that plaintiff
might further harm the daughter. McKay also advised plaintiff that he
had repressed memories of his abusive conduct and that he should begin
psychological treatment. Plaintiff paid defendants over $3,000 for
services rendered to his daughter during 1992.
  In 1994, the father sued McKay and her professional association.The
first amended complaint lists 17 counts, but only causes of action
concerning two issues were considered on appeal: the negligent
treatment of Jane Doe which deprived plaintiff of the loss of his
daughter's society and companionship, and intentional interference
with the parent-child relationship. The trial court had dismissed
these claims, holding that they were not recognized by Illinois
law. The other claims remain pending at the trial court. The appeals
court noted that a third party generally cannot maintain a malpractice
action in the absence of a direct physician-patient relationship
between the doctor and the patient. The court reversed dismissal of
the claims, holding that a special relationship existed between the
patient and the third party under the doctrine of transferred
  The appeals court cited Renslow v. Mennonite Hospital, 67 Ill.2d 348
(1977), in support of its decision. In Renslow, the Illinois Supreme
Court held that logic and sound policy required the creation of a
legal duty on the part of a hospital to a child born of a mother
treated in the hospital. That court noted that derivative actions,
such as those of a husband or parent for the loss of the wife's or
child's society, demonstrate that the law has long recognized that a
wrong done to one person may invade the protected rights of one who is
intimately related to the first and therefore recognizes a "limited
area of transferred negligence."
  The appeals court said that transferred negligence was applicable to
the "unique circumstances" in this case. "In determining whether a
duty exists, the court must weight the foreseeability of the injury,
the likelihood of the injury, the magnitude of the burden of guarding
against it, and the consequences of placing that burden on the
defendant," citing Gouge v. Central Illinois Public Service Co., 144
Ill.2d 535, 542 (1991).
  "Key to this finding are the special relationship plaintiff shares
with his daughter and the therapist's action to bring plaintiff into
the treatment process," the court said. "Once plaintiff was immersed
in his daughter's treatment process, as a quasi-patient himself, it
was not only reasonably foreseeable, but a virtual certainty, that
McKay's conduct would harm plaintiff's relationship with his
daughter." Therefore, the court said, the defendants' duty to use
reasonable care in the treatment of their patient extended to the
father, referring to Tuman v. Genesis Associates, 894 F.Supp. 183, 187
(E.D. Pa. 1995).
  The court said that "[t]he risk and magnitude of harm to our
society, namely, tearing a family apart without regard to the manner
in which false accusations of sexual abuse are made, is so significant
that it requires the protection of our law. A therapist's allegedly
erroneous conclusion that a patient has been sexually abused by a
parent endangers the parent-child relationship, and that where the
therapist draws the accused parent into the patient-child's treatment,
accusations of sexual abuse are undeniably devastating and may not be
made with impunity and disregard of the therapist's obligation of
reasonable care."
  The court continued, "The therapist is in the best position to avoid
such harm and is solely responsible for handling the treatment
procedure. Defendants could have warned plaintiff and his daughter of
the controversial nature of repressed memory therapy in separate
sessions. We therefore hold that in a case such as this involving
repressed memories of sexual abuse, where the parent is brought into
the treatment process by the therapist, the therapist's duty to the
patient to use reasonable care in the treatment process is extended to
the parent."
  Attorney for plaintiff John Doe is Zachary M. Bravos of Wheaton,
  (1) See FMSF Brief Bank #46.
          Minnesota Court of Appeals in Unpublished Opinion   
              Declines to Recognize Duty to Third Party
               Strom v. C.C., 1997 Minn. App. LEXIS 327
                            March 18, 1997
In March 1997, a Minnesota Court of Appeals declined to extend the law
to recognize a duty to third-party non-patients when there is no
contractual relationship, duty to warn, or duty to control, citing
McElwain v. Van Beek, 447 N.W.2d 442, 445-46 (Minn. App. 1989), review
denied (Minn. Dec. 20, 1989). It affirmed summary judgment dismissing
defamation claims against two nephews who had alleged that Everald
Strom had sexually abused them as children. It also affirmed dismissal
of defamation and negligence claims against the nephews' therapists.
  In its unpublished opinion, the court stated that not recognizing a
duty to third-party non-patients is consistent with established public
policy because imposing a duty on therapists to protect the interests
of falsely accused individuals would adversely affect the interests of
sexual abuse survivors in effective and uninterrupted therapy. (2)
  The court noted that with a charge of negligence, the inquiry is not
whether there is probable cause to believe that Strom actually
sexually abused his nephews. The issue is whether the nephews or the
therapists had a sufficient basis for believing that his own
statements regarding Strom's conduct were true. The court wrote it
could not conclude the nephews did not have a valid reason for
believing they were speaking the truth because some of the memories
allegedly developed prior to therapy. The court also concluded that
the therapists had reasonable and probable cause for the statements
they made. On the other hand, the court recognized that one nephew's
memories "may not provide an accurate source of information as to
Strom's past conduct" and he would "not be allowed to testify as to
memories that came about as the result of therapeutic hypnotic recall,
robust memory recall, or recalled memory from traumatic amnesia."
  (2) The court cited Bowman and Mertz (1996), "A dangerous direction:
Legal intervention in sexual abuse survivor therapy, 109 Harv. L. Rev.
549, 586-90.
             Question of Duty to Third Party by Therapist 
              May Be Considered by Federal Appeals Court
On March 22, a U.S. District Court certified an interlocutory appeal
in a third-party suit, Lindgren v. Moore, 1996 U.S. Dist. LEXIS 3450.
The order refers to an earlier Memorandum Opinion, Lindgren v. Moore,
907 F.Supp. 1183 (U.S. Dist., Sept. 29, 1995) which had let stand two
counts against a therapist and her supervisor for IIED and loss of
society. Defendants wish to appeal the denial of their motion to
dismiss those claims with a decision on whether Illinois law
recognizes a third party cause of action and whether defendant
therapists owed a duty to any plaintiff which was breached here. In
certifying the appeal to a Federal Appeals Court, it was noted that
because any later trial decision could require reversal if decided
incorrectly, it is prudent to decide the question of duty now.
           Jury Finds for Doctor in Repressed Memory Trial
          Sullivan v. Cheshier, U.S. District Court, verdict
                            April 2, 1997
On April 2, 1997, a U.S. District Court jury found in favor of
unlicensed clinical counselor Dr. William Cheshier. The suit against
Dr. Cheshier had been filed early in 1993 by the parents of one of his
patients. The parents alleged that the doctor, using hypnosis, had
implanted false memories of sexual molestation in their daughter.
  In 1994, U.S. District Judge James B. Zagel (3) had allowed the
parents to proceed to trial on three counts: malpractice, loss of
companionship and society, and public nuisance (persons injured by one
who practices clinical psychology without a license have a right of
action under the Illinois Clinical Psychologist Licensing Act).
However, on the day of trial, U.S. District Judge Elaine E. Bucklo
limited jury consideration to only one count: loss of society and
companionship. In addition, Judge Bucklo ruled that the plaintiffs
must prove the injury to their family relationship was inflicted by
defendant's reckless or intentional acts which were directed toward
  At trial, the plaintiffs' daughter, Kathleen, age 30, admitted that
she had not thought about being the victim of childhood abuse until
she was treated by Cheshier and that after only a few sessions,
Cheshier suggested to her that hypnosis might offer some insight into
her troubles. She agreed to undergo hypnosis and after several
sessions she claimed she gradually realized she had been physically
tormented and molested by an older brother. Kathleen denied, however,
that her therapist's actions injured her family relations.
  In reviewing this verdict, it may be useful to recall the summary of
issues as given by Judge Zagel in March 1994, "Dr. Cheshire told [the
Sullivans] he had hypnotized Kathleen Sullivan and while under
hypnosis she stated that she was abused by an older sibling...The
Sullivans conducted an investigation of the truth of the statements
and found no evidence to corroborate the statements and have a witness
who denies the truth of the statements. Prior to Dr. Cheshier's
hypnosis, Kathleen Sullivan never made similar statements. Finally,
there is the statement by Kathleen Sullivan while being treated by
Dr. Cheshier, arguably admissible under F.R.E. 803(2) or 803(3), that
she would decline all family contacts unless family members admitted
the statements were true...There is no question that after the
statements were made by Kathleen Sullivan her relations with her
parents and siblings changed for the worse. It would be hard to doubt
that the family relationship would be seriously and negatively
affected in this situation. A trier of fact could reasonably lay it at
Dr. Cheshier's door."
  Thomas P. Ward, attorney for the Sullivans, said that a motion for
new trial has been filed in District Court.
  (3) Sullivan v. Cheshier, 846 F.Supp. 654 (N.D. Ill., Mar. 2, 1994).
                    Minnesota Psychologist Accused
                of Planting False Memories in Patient
 Doe v. Fredrickson, District Ct., Second Judicial Dist., Ramsey Co.,
                  Minnesota, Case No. C6-97-3540 (4)
In a Complaint filed April 4, 1997, Dr. Renee Fredrickson, a St. Paul
psychologist and author of a book on repressed memory therapy was
accused by a former client of implanting horrifying false memories.
The woman, identified as Jane Doe in the lawsuit, alleges that
Fredrickson negligently used hypnosis, guided imagery, dream
interpretation, automatic writing, "body memories" and other "memory
recovery" methods to implant terrifying false memories of "ritual cult
abuse," torture, and murder. Doe alleges that Fredrickson failed to
obtain informed consent or to inform her that the techniques used are
known to produce vivid, convincing, but false "memories." As a result
of Fredrickson's "treatment," Doe became suicidally depressed for the
first time in her life and made false accusations to her immediate and
extended family. Her family relationships were shattered by these
  Doe's husband attended some of his wife's therapy sessions and under
the "advice" of Fredrickson came to believe his wife's emerging
"memories" were true. He witnessed his wife's deterioration while
under Fredrickson's "treatment" and was told that such deterioration,
including suicidal depression, was a sign that the "repressed
memories" were surfacing and that the "cults" had "programmed his wife
to kill herself if she ever remembered or told others about the cult."
  Jane Doe and her husband have also filed complaints to the Minnesota
Board of Psychology seeking the revocation of Fredrickson's license to
practice psychotherapy.
  Jane Doe is represented by William Mavity of Minneapolis and
R. Christopher Barden of Plymouth, Minn.
  (4) See, FMSF Brief Bank #138.
  (5) Fredrickson, R. (1992), Repressed Memories: A Journey to
Recovery from Sexual Abuse, New York: Simon and Schuster.

  Editor's note: In March 1997, U.S. District Court Judge John R.
  Padova revisited two of the many lawsuits which involve a
  Philadelphia mental health clinic called Genesis Associates,
  psychologist Patricia Mansmann and social worker Patricia Neuhausel
  (6). As described below, both of these suits are spin-offs from a
  third party suit filed in 1994 against Mansmann, Neuheusel and
  Genesis Associates by the parents of a former patient (7).
                     Pennsylvania Court Considers
                Whether Patient Could Have Understood 
         That Therapy Caused Injury While She Was In Therapy
  Lujan v. Mansmann, Neuheusel, Genesis Associates, 1997 U.S. Dist. 
                      LEXIS 2960 March 14, 1997
In this case, brought by former patient, Brooke Lujan against Genesis
Associates, U.S. District Court Judge John R. Padova rejected
defendants' motions to dismiss all but one of the charges against
them. Defendants had argued that Lujan's claims were barred by the
statute of limitations. Lujan had entered treatment with them in 1990
but did not file her initial complaint until July of 1996.
  Judge Padova left standing claims of negligence, breach of contract,
willful, reckless and wanton misconduct, intentional (IIED) and
negligent infliction of emotional distress, and breach of
confidentiality. In doing so, the court applied the objective standard
used in Pennsylvania to determine whether a reasonable person in
plaintiff's position would have been unaware of the salient facts. The
court quoted extensively from Plaintiff's Amended Complaint and
decided that it could not, at this stage of the proceedings, conclude
that the time it took Lujan to discover any injury, or the cause of
that injury, was unreasonable as a matter of law.
  Significantly, the court continued, "the dynamics of the
psychiatrist-patient relationship contribute to this finding. Patients
do not immediately assume their treating psychiatrists are
perpetrating tortious acts through harmful and psychologically
damaging treatment. Instead, patients are reluctant to either impute
ulterior motives to the advice of their psychiatrist or automatically
question the propriety of the psychiatrist's treatment. Lujan may have
had no idea, as a lay-person, what 'proper' and 'improper' treatment
was. Lujan, quite typically, may have assumed her psychiatrist was
providing proper treatment and may not have become suspicious until
December, 1995."
  Lujan's Complaint states that it was not until December 1995 when
she received information about her parents' lawsuit (7) against her
therapist, that she "began to question the veracity of her memories
and the appropriateness of the treatment she received from
defendants." She further states that defendants failed to meet a
standard of care by encouraging her "to believe in certain memories,
including memories of satanic abuse, satanic murders and deviant
sexual assaults;" convincing her that "she was being stalked by a cult
and that her life was in danger;" and inducing her to undergo plastic
surgery "to alter her features so that the 'cult' would have a more
difficult time finding her."
  The Complaint also alleges that defendants encouraged her to detach
herself from her parents and cut all communication with them except
for financial matters; prevented her from completing her college
studies; and did not request needed medical treatment in a timely way
following "rage therapy."
  (6) Several other lawsuits are currently pending. See FMSF
Newsletter, Oct. 1996.
  (7) The first lawsuit against Genesis Associates was filed in 1994,
see, Tuman v. Genesis, 894 F.Supp. 183 (U.S. Dist., July 20, 1995);
Tuman v. Genesis, 1996 U.S. Dist. LEXIS 5406 (April 25, 1996). In
that case, parents of a Genesis patient alleged that through the
psychological counseling provided to their daughter, false memories of
satanic rituals were implanted in her mind. The parents alleged that
defendants had encouraged their daughter to move to another state and
cut off communication with them. In 1996 charges against psychologist
Mansmann were dismissed by Judge Padova who agreed that there was no
evidence that Mansmann had treated the daughter. In June 1996, the
remaining defendants settled out of court. See also, FMSF Brief Bank
#60 and PBS Frontline Film "Divided Memories" April 11, 1995.
                    Pennsylvania Psychologist Sues
               Parents of Former Patient for Defamation
 Mansmann v. Tuman, et al., 1997 U.S. Dist. LEXIS 3291 March 13, 1997
In 1996, after psychologist Patricia Mansmann was granted summary
judgment from a third party malpractice suit,7 she sued the parents
and the parents' attorney who had filed the earlier action against
her. She alleged that the Tumans and their attorneys had acted "with
actual malice" and "merely for purposes of harassment or to
maliciously injure" her. U.S. District Judge John R. Padova dismissed
all counts against the defendants except the defamation charge against
the Tumans and the charge of interference with business relations
against the Tumans and one of their attorneys. Judge Padova noted that
Mansmann's Amended Complaint "is long on Defendants' intentions and
short on their implementation of the intentions."
  Judge Padova dismissed the charges that the Tumans and their
attorneys had made wrongful use of civil proceedings by filing the
suit against her without fully investigating the allegations. Judge
Padova notes that although Mansmann alleges they had no probable cause
to continue the lawsuit, based on evidence adduced during discovery,
she gives no clue as to what that evidence might have been nor does
she support her claim of improper motive.
  Charges of defamation, interference with business relations and
intentional infliction of emotional distress stemmed from allegations
that the Tumans (and their attorneys) made statements that Mansmann
had committed professional malpractice and misconduct, had given their
daughter treatment she did not need for monetary gain, and had forced
the daughter to distance herself from her parents and to detach
entirely from them. Mansmann alleged that such statements were made
"regularly and with malice" in documents to the Court, various police
and other investigative agencies, orally at deposition, to
psychological professional organizations, at public meetings, and to
the media. Mansmann also claimed that the defendants attended numerous
meetings in an attempt to put her out of business and see her stripped
of her license to practice.
  The court held that judicial privilege would apply to statements the
Tumans and their attorneys made in the context of their suit, but not
to statements made in other contexts. Judge Padova concluded that,
accepting all the facts alleged in the Amended Complaint as true and
liberally construing it in the light most favorable to Plaintiff, the
defamation and interference claims survives the Tumans' motion to
dismiss. The interference claim also survives against one attorney who
attended meetings. However, Judge Padova dismissed all claims of
intentional infliction of emotional distress, finding that the conduct
alleged was not sufficiently extreme or outrageous as to sustain that
cause of action.
                   Father Wins Million Dollar Jury
                  Award Against Minirth Meier Clinic
               WORLD Magazine, April 5, 1997, Bob Jones
Early in April 1997, an Atlanta jury awarded a father $1 million in
compensatory damages after he was falsely accused of abusing his minor
children. The father and his wife had sued a Minirth Meier New Life
Clinic after the clinic reported suspected abuse of his minor children
to DDS simply because he had told them he himself had been physically
abused. The father phoned the clinic after hearing a radio broadcast
saying that those who were abused as children are likely to grow up to
be abusers themselves.
  After the jury verdict in his favor, Mr. Rogers said that more
important than the money was the return of his good name.
               Two Panels of Michigan Court of Appeals 
        Reach Different Conclusions in Repressed Memory Cases
Two recent Michigan Appeals Court decisions have drawn different
conclusions about the intent of the Michigan Supreme Court decision,
Lemmerman v. Fealk, 534 N.W.2d 695 (Mich., 1995), (8) in decade-
delayed cases where there is some admission by the defendant. In both
cases, the defendants admitted there had been some contact years
earlier but denied any sexual abuse.
  One court (9) noted that the Lemmerman opinion specifically stated
that under current Michigan statutes, even upon presentation of
"objective and verifiable evidence" of plaintiff's claim, neither the
discovery rule nor the insanity exception extend the limitations
period for tort actions allegedly delayed because of memory
repression. That court concluded that footnote 15 to the decision does
not carve out exception to the general holding in Lemmerman but merely
deals with the retroactive effect of the decision. If the Lemmerman
court had intended to create an exception to the statute of
limitation," it would have done so in the test opinion, rather than in
the footnote."
  Four days prior to the Guerra ruling, another panel of the Michigan
Court of Appeals,10 in an unpublished ruling, allowed a repressed
memory claim after concluding that Lemmerman did "not address cases in
which the defendant admitted sexual contact...Express and unequivocal
admissions remove those cases from the area of stale, unverifiable
claims such as the two repressed memory cases in Lemmerman."
  (8) See, FMSF Newsletter, July/August 1995 and FMSF Publication
  (9) Guerra v. Garratt, 1997 Mich. App. LEXIS 92 March 14, 1997.
  (10) Demeyer v. Archdiocese of Detroit, et al., Lawyers Weekly,
No. 28395 (4 pages), March 1997, unpublished per curiam.
               Nebraska Supreme Court Affirms Dismissal
                       of Repressed Memory Suit
       Teater v. State of Nebraska, 252 Neb. 20, March 14, 1997
The Nebraska Supreme Court affirmed dismissal of a repressed memory
claim, finding it barred by the statute of limitations. The court
upheld the trial court's finding that plaintiff, Teresa, age 36, had
failed to meet the burden of proof that she suffered from a mental
disorder which would prevent her from understanding her right to
maintain a legal action. Although Teater alleged in her petition that
she was unaware of any sexual abuse by her foster father, the court
found that Teater was aware of the alleged abuse when she reported it
to school officials at the age of 14. The court found that Teater's
denial of knowledge of the abuse thereafter was inconsistent with her
own actions.
  Teater sued the State for negligence in its failure to supervise and
monitor her placement with the foster family. She states that it was
not until 1992, when she learned she was a ward of the state during
the period of the alleged abuse, that she was able to discover her
cause of action against the state. The court held that because Teater
had not sufficiently pled that the state wrongfully concealed the fact
that her status was still as a foster child, that the theory of
fraudulent concealment could not be invoked.
  Therefore, the court held that the cause of action as pled was
barred by the statute of limitations.
           Canadian Repressed Memory Case Ends in Acquittal
        Regina v. Ross, Supreme Court, Northwest Territories, 
                Canada, No. 02958, March 11, 1997 (11)
After hearing the evidence in a Canadian criminal case based on
repressed memories, Justice V. A. Schuler found that a young woman's
claims of sexual abuse, including intercourse with a neighbor over 10
years earlier, included many inconsistencies that in combination
caused "a great deal of concern about the reliability of the
complainant's evidence." Justice Schuler concluded that the Crown had
not met its burden of proof beyond a reasonable doubt. Therefore, the
defendant was found not guilty.
  Justice Schuler specifically noted the contradictory testimony from the
complainant and the complainant's therapist as to how the "memories"
developed. The complainant stated she blocked the memory until her
therapist asked her repeatedly whether the defendant had abused her and
told her to think "really hard" about it. The therapist was adamant that
she had not told the complainant to think really hard about whether the
accused had abused her and denied being the first to bring up the question
of abuse.
  Justice Schuler's discussion of these discrepancies is quite interesting,
"I have to ask myself, Did these further memories flow from, were they
suggested by, the idea that the complainants' problems might be explained
by the sexual abuse? ...If I reject the complainant's evidence about how
the disclosure came about and accept the [therapist's] evidence that she
had not been the first one to bring up the question of abuse, then I am
still left with the question about the further memories after the
counseling session, and I am left with a question about the reliability of
the complainant's memories generally."
  (11) Transcript of Reasons for Judgment delivered by Justice V.A.
Schuler on March 11, 1997 available as FMSF Brief Bank #139.
                   Eighth Circuit Court of Appeals
                   Revisits Child Sexual Abuse Case
  United States v. Rouse, 1997 U.S. App. LEXIS 6659, April 11, 1997
A three-member panel of the 8th Circuit Court of Appeals reconsidered
the convictions of four Native American men for sexual abuse of
several young children. In November 1996, the divided panel had
reversed and remanded the cases for new trial on the grounds that the
district court erred in excluding certain expert opinion testimony
regarding the effect of repeated questioning on the young children and
in denying defendants' motion for independent pretrial psychological
examinations of the abused children (12).
  On reconsideration of the parties' contentions, the panel, again
divided, now affirmed the convictions. The opinion concluded that the
defense had not established sufficient cause to conduct additional
medical or psychological examinations of the children and therefore
the district court did not abuse its discretion in declining to order
DSS to subject the children to further medical or psychological
  The new majority of the 1997 Circuit Court panel now concluded that
exclusion of a portion of the defense expert testimony that opined on
the impact of questioning by specific individuals was harmless error
-- a conclusion with which the dissent strongly disagreed. The dissent
stated that the jury needed the excluded expert testimony to render a
truly informed judgment about whether the children's testimony
resulted from implanted memory.
  (12) A summary of the panel's ruling in November 1996 can be found
in FMSF Newsletter, Feb. 1997, pp 11-12. U.S. v. Rouse, 100 F.3d 560
(8th Cir., 1996).
                            Legal "Briefs"

  The unpublished decision from a Washington State Appellate Court in
the case, Jamerson v. Vandiver, reported in last month's FMSF
Newsletter has been published in part as Jamerson v. Vandiver, 1997
Wash. App. LEXIS 492 (filed April 7, 1997).

  On April 15th, the FMS Foundation submitted an amicus curiae brief
to the Tennessee Supreme Court on behalf of the Defendant/Appellee in
the case, Hunter v. Brown, No. 03S01-9607-CV-00070. The brief
considered issues raised by "repressed memory" claims under the
reasonable person standard for application of the discovery rule. It
also reviews factors leading to the development of false memories, the
repressed memory debate, current scientific findings, and relevant
case law in other jurisdictions. The brief is available as FMSF
Publication #812.

 /                                                                  \ 
 | The first annual meeting of the Rational Feminist Alliance of    |
 | CSICOP (Committee for the Scientific Investigation of Claims of  |
 | the Paranormal) will be held on June 6 and 7 in Boulder, CO. One |
 | focus of the conference is the impact of gender politics and     |
 | feminist rhetoric on the field of psychology. Speakers include   |
 | Elizabeth Loftus and Debra Nathan. The keynote address by Carol  |
 | Tavris is entitled "Back to Rationality."                        |
 |     For information contact:                                     |
 |           Center for Inquiry - Rockies                           |
 |           P.O. Box 2019                                          |
 |           Boulder, CO 80306                                      |
 |           303-447-1429                                           |
 |                                      |

                       B O O K   R E V I E W S
                           Second Thoughts:
  Understanding the False Memory Crisis and how it could affect you.
                           Dr. Paul Simpson
                       Thomas Nelson Publishers
                     246 pages, paperback $12.99
                      Reviewer: Robert McKelvey

  "A local chapter of the FMS Foundation had just been formed in the
  Phoenix area...I decided to attend their next meeting, convinced
  that I would encounter a room full of pedophiles and satanists. I
  couldn't have been more wrong. Here were families that represented
  the very heart of the American family. They had lived productive
  lives, raised their children, worked in their professions. Their
  grown children had gone into therapy, and from there, with little
  warning, the nightmare had begun..."

  The speaker is Dr. Paul Simpson, describing how he began his
tortuous climb from the dark pit of repressed-memory belief back into
the light of reality.
  In the wacky world of regressionist therapy, psychologist Simpson is
a rare figure -- rare because he is both a dedicated scientist AND a
devoted Christian. He also is a onetime regressionist-therapist who
embraced repressed memory therapy (RMT), infected clients with the
plague of false memories, then saw the light, retracted, and tried to
salvage the lives of those he had harmed. Today Dr. Simpson wields his
speaking, writing, and teaching skills in a crusade to stamp out the
RMT doctrine he views as monstrous.
  "...I write to you out of moral imperative," Simpson proclaims.
"What is happening in the False Memory Crisis is wrong, horrifically
wrong..."  "Second Thoughts" is Simpson's way of presenting the case
against RMT in a readable fashion. The author deliberately avoids what
he calls a "textbookish" writing style in favor of one more familiar
to general readers. In doing this, however, he avoids any temptation
to "write down" to his audience.
  The book devotes considerable attention to what science knows about
memory-how it works and how it doesn't work. Simpson also devotes a
chapter to his argument that Christian counselors who practice
regressionist therapy are flouting church principles, such as "Honor
they father and thy mother..." His conclusion: "regressionism is not a
doctrine taught anywhere in the Bible." "The reality is that the
Christian regressionist and client are not engaging in an act of
faith," writes Simpson. "What they're doing is classic hypnotic
  Although Dr. Simpson's book should become a powerful weapon in the
inter-church struggle over THE repressed-memory issue, I found it
equally valuable for providing insights into some of the mysteries of
the false memory crisis.
  One mystery is this: Why is the false memory crisis no longer
exploding? Speakers at the recent Baltimore FMSF conference
acknowledged that the foundation is receiving fewer contacts; lawsuits
have radically fallen off; the press publishes more and more positive
stories debunking recovered memories; retractors and their families
are winning million-dollar judgments against therapists; insurance
companies are refusing to insure RMT therapists.
  Despite all these signs, there is no indication that
psychotherapists have revised their belief in regression therapy. As
"Second Thoughts" points out, one study showed that 71 percent of
doctoral level psychologists have made use of regression techniques in
an effort to recover repressed memories in clients. Another study
finds "a stunning 83 percent of therapists believe that hypnosis
counteracts the defense mechanism of repression."
  Most observers have seen little change in the views of regressionist
practitioners. Simpson himself concedes he had little success in
efforts to change the minds of zealous Christian regressionists.
  So, once more, why is the memory crisis no longer exploding? Perhaps
we've been looking in the wrong place for the answer. Most observers
focus on the therapist as the main partner in the RMT folie a deux,
while minimizing the role of the client. Simpson offers another
  In the chapter "Monsters From Within," Simpson points to research
that shows a small but significant percentage of the population (4 -
10 percent) is highly susceptible to hypnotic suggestion. These people
are described as "fantasy prone" and "Grade Five Personalities."
Whatever the label, they are so easily hypnotized that they are able
to put themselves in a trance without the aid of a hypnotist. (An
example would be Paul Ingram, the imprisoned Washington state father
who could implant false memories in himself.)
  We frequently hear this argument about the false-memory phenomenon:
"It could happen to anyone." But could it?
  Using Dr. Simpson's data, we might raise this question: Is being a
"Grade Five" a necessary prerequisite for becoming an RMT dupe? And is
it possible that the supply of these candidates is quite small, not
enough to sustain the RMT craze at a fever pitch indefinitely? To find
out, we need to look at women who entered regression therapy, but
never abandoned reality in favor of false memories.
  While readers should find "Second Thoughts" a persuasive argument
against RMT's True Believers, some may find a few regrettable
omissions in the book. One is the lack of an index. Another is the
shortage of details when Dr. Simpson talks about his own experience as
a regressionist therapist. He is silent about the number of clients
treated; how many of them were saved; how many continue to revel in
their repressed memories. Most importantly, he fails to tell how many,
if any, of his clients never bought into the theory at all.
  Regardless of these minor quibbles, readers all can agree with Dr.
Simpson's conclusion about RMT believers and victims: "The funny thing
is, truth never asks our permission, it just is. And those who fail to
conform their lives to truth are ultimately doomed to be crushed by

  Robert McKelvey retired after 20 years as a reporter for the
  Cleveland Plain Dealer. He is currently working to educate church
  leaders about the harm that can come to families because of false
|                             Correction                             |
|                     from the issue of June 1                       |
| In the May newsletter (p.14) it was incorrectly stated that        |
| reviewer Robert McKelvey worked for the Cleveland Plain  Dealer.   |
| The correct information is as follows: during his 44-year career   |
| as a newspaperman, Mr. McKelvey worked for the Detroit Free Press, |
| the Detroit News, the Toledo Blade, the Ft. Wayne Journal-Gazette, |
| the South Bend Tribune, the Chicago Sun-Times, the New York Daily  |
| News, the Indiana Daily Student and the Rochester (IN)             |
| News-Sentinel.                                                     |

                Review of The Counseling Psychologist:
                Delayed Memory Debate, 23 (April 1995)
              Robyn M. Dawes, Carnegie Mellon University

  This issue of The Counseling Psychologist has been widely advertised as one
devoted entirely to the "delayed memory debate." Most of it is, but rather
than consisting of a number of articles of roughly equal length and
importance, it contains a major paper by Caroline Zerbe Enns, Cheryl L.
McNeilly, Julie Madison Corkery, and Mary S. Gilbert (University of
Iowa)-followed by a number of comments of people who can be roughly
categorized as "pro" or "anti" the attempt in therapy to recover repressed
memory of sexual abuse, particularly in satanic cult rituals.
  The major contention of the Enns et al article is that the debate over the
validity of delayed memories must be understood "within the historical
context." That begins as a reasonable hypothesis, because there are many
phenomenon that are best understood with context. What is much more
questionable is the claim that a phenomenon that is very difficult to
understand (the nature of the recovered memories) can be understood only by
first assessing something that is even more difficult to understand (a
broad historical context involving a "male dominated" culture).
  Moreover, this broader context is not understood on the basis of what could
be called "science," but rather on the basis of ideology. Thus, the core of
the argument is that since the study of recovered memory might be best
understood by investigating it within the context in which it occurs (a
possibly true argument), ideological assertions about this context imply
factual knowledge about delayed memory (an unjustifiable leap from the
premise). Many of these understandings, moreover, are just assertions. For
example, some authors are quoted approvingly as stating: "We believe that
the greater the degree of male supremacy in any culture, the greater the
likelihood of father-daughter incest" (pg. 193, italics added). Enns et al.
themselves move from belief to appearance when they write: "However, the
outcry about false memory seems to reflect in part the type of reaction
that often occurs when women and victims appear likely to gain real power
in a tangible recourse for gaining justice"(pg. 197, italics added). But
what it is that is apparently reflected, and other appearances, do not
constitute justification. The authors realize that gap when they write:
"until further research is conducted, it is impossible to draw any firm
conclusions about the accuracy of these memories"(pg. 207). In the
meantime, unfortunately, they move from belief and appearance to made-up
statistics. (No one could possibly estimate the percentage of reports that
are accurate versus inaccurate on the basis of what is currently known.)
  It is possible to reach a valid conclusion from a dubious premise (as a
form of "material implication"), and Enns et al. occasionally offer pretty
good advice-mainly about being cautious. In the meantime, however, the
authors accept many assertions as factual for which there's very little
evidence at all. For example, they believe that abreaction, or at least
"working through" previous negative experiences (especially childhood
ones), is an important part of therapy. That is their prerogative as
therapists. As commentators, however, they should not refer to such
phenomenon as if they were established facts, which they are not. The "Dodo
bird" finding-that aside from specific cognitive and behavioral "protocol"
therapies for well-defined problems (e.g. phobias, unipolar depression) all
those based on the "therapeutic alliance relationship" do about equally
well-contradicts the idea that there are certain critical characteristics
of good therapy.
  Finally, I question the statements that transformation from visual
to verbal form are necessary in order to understand anything, because
many of us progress in the opposite exact direction; that is, we
believe we do not understand anything until we have transformed the
mere words describing it into some sort of visual coherence, even
"vague visual forms." There is a certain imperiousness in arguing that
"if the client's memory consists primarily of imagistic or motor
impressions rather than verbal, lexical memory, it may be possible for
clients to arrive at 'gut feelings' about the past without achieving
full verbal recall" (pg. 240, italics added)-without suggesting that
this "full verbal recall" may in fact be a source of distortion not
only of historical reality but of internal feelings and attitudes as
well. Those of us who change in the opposite direction do not insist
that everyone who things verbally has not "achieved understanding"
until they "progress" in our preferred direction.  Nevertheless, I
want to emphasize in finishing my discussion of the Enns et al.
article that they do often urge people to be cautious about
interpreting what a recovered memory means-in particular assuming it
is (is not for that matter) historically accurate. The fact that they
do not urge similar caution along the way about such things as using a
Gestalt-chair experience is secondary. Even the vague and
platitudinous nature of their final comments about training and social
change issues can be forgiven, because that quality is not unique to
them, but shared with many people who propose "standards" based on
training and "consideration" as opposed to what practitioners actually
do. (The platitudinous nature of these recommendations can be
understood by inserting the word "not" in them. For example, we should
not encourage faculty and students to pursue research on child sexual
abuse in order to understand it better.)
  The commentators contributions can be pretty well predicted from their
reputations. Beth Loftus emphasizes "primum non nocere" and discusses
burden of proof. She also writes (pg. 302): "Although many of the women
claimed they had corroboration for their abuse, Herman and Schatzow never
independently checked the corroboration, not did they show that any of the
women with the 'severe memory deficits' had any independent corroboration
whatsoever." Yes. Stephen Lindsay generally agrees with Loftus when he
discusses problems of iatrogenic illusory memory.
  Unsurprisingly, I am more critical of the comments by John Briere and
Christine Courtois than of the comments by Lindsay and by Loftus. One
statement I found particularly puzzling in Briere's comments is the
following: "As psychologists know, science (by definition) cannot rule out
the null hypothesis-in this case, that memory 'repression' or dissociation
never happens. At most, one might establish that some cases of so-called
repressed memories are actually confabulated. Even were this to be shown to
be a reliable phenomenon, the issue would remain whether the presence of
false reports rules out the reality of the true reports,"(pg. 291). First,
often all we do is to rule out null hypotheses (by finding results that are
extremely improbable if these hypotheses are true). Generally, our ruling
these out involves a bit of convoluted reasoning that usually takes the
form: if nothing is there, I found an unusual value of it; therefore, I
reject the null hypothesis that nothing is there. We can however rule out
with certainty the null hypothesis that repression and dissociation never
occur by finding a single case in which they do. Moreover, no one ever
claimed to my knowledge that the presence of a false positive can rule out
the possibility of a true positive. The statement is just baffling.
  The comments of Christine Courtois are, however, a bit more than
baffling. After discussing scientific standards and a need for
collaboration (not corroboration) she writes: "Unfortunately, a number
of memory researchers are erring in the same way that they allege
therapists to be erring: They are practicing outside of their areas of
competence and/or applying findings from memory analogues without
regard to their ecological validity and making misrepresentations,
overgeneralizations, and unsubstantiated claims regarding therapeutic
practice" (pg. 297).
  That statement can be derived from the -- in this reviewer's view
very unfortunate -- equation of training with competence, which is
made throughout the American Psychological Association's Ethics Code.
Thus, people who do not have training in recovering repressed memories
really shouldn't comment on the process, while people who do have
training in doing so are by definition competent to do so. The point
is that the critics are coming from a basis of what is known about
memory in general. There may be something different about memory of
trauma, but if so, it is up to the person claiming this difference to
specify what it is, and provide evidence for its existence. Instead,
what we have is a hypothesized difference, and equating the
hypothesized difference with a true one (without stating exactly what
it is), Courtois concludes that generalizing without recognizing this
difference is invalid.
  Finally, Laura S. Brown also accepts the idea that it is easier to
understand broad political matters than to understand memory-so that
"political understanding" provides specific understanding. She also
has some very unusual comments, for example that believing that
childhood experiences have little impact implies that "people simply
cannot change" (pg. 313). She also relates the answers to the
questions of "Why this issue?" and "Why now?" to the 1994 election
results and to the horrible (in this writer's view) practice of
treating children charged with certain crimes as adults and filling
our prisons with people failing "three strikes" laws. The problem with
these connections is that an equally good case could be made that it
is the authoritarian belief in experts in the absence of corroboration
that is related to reactionary political stands (in fact, a return to
practices prior to the Magna Carta, which spelled out the need for
corroboration in Chapter XXVIII). At least those of us who abhor
courts' acceptance of "expert opinion" as a modern type of
corroboration that can send people to jail (or deny children of a
parent) might "find it plausible" that a reactionary and vindictive
"political context" is positively related to belief in recovered
memory, rather than negatively related. Not having done a survey of
even an informal nature about the relationship between conservative
versus liberal political ideology and position about recovered memory,
I cannot state what the relationship is. But Laura Brown's assertions
inadvertently illustrate how the belief about the relationship is a
matter of ideology, not of evidence. Given that it is possible to make
a plausible ("seems to reflect" -to use the terminology of Enns et al)
argument for a relationship in the exact opposite direction of that
postulated by Brown, her assertions illustrate quite neatly the flaw
in attempting to assess the "political context" first in order to
understand the actual evidence later, if at all.

  Robyn Dawes, Ph.D. is a University Professor of Psychology in the
  department of Social and Decision Sciences at Carnegie Mellon
  University. He is the author of House of Cards and Rational Choice
  in an Uncertain World, and is a member of the FMSF Scientific
  Advisory Board.

     | Our daughter is walling in a sea of polluted memories." |
     |                                                 A Dad   |
      M E M O R Y   A N D   R E A L I T Y:   N E X T   S T E P S
                  V I D E O   D E S C R I P T I O N

                          March 22-23, 1997

TAPE 222  160 minutes (approx.)
  Welcome and Introductions
  Making A Difference
    PAMELA P. FREYD, Ph.D.  (Introduced by Andre Brewster, Esq.)
  What We Still Need to Know
    ELIZABETH LOFTUS, Ph.D.  (Introduced by P. T., Ph.D.)

TAPE 223  160 Minutes (approx.)
  Part 1 Legal Task Force, ANDRE BREWSTER, Esq. Moderator
  The Foundation as Friend of the Court
  Families and the Courts:  Report on the Legal Survey
  Part 2 Panel, RALPH SLOVENKO, J.D., Ph.D. Moderator
  Family and Retractor Panel:  Dealing with the Legal System

TAPE 224  120 minutes (approx.)
  Helping Families is to Help Everyone
    PAUL R. McHUGH, M. D.  (Introduced by Eleanor Goldstein)
  Family Panel: The Wisdom of Families and Retractors 
    ALLEN FELD, LCSW Moderator
    BERNICE SCHAFFNER.  (Introduced by Charles Caviness)

TAPE 225  100 minutes (approx.)
  Reforming the Mental Health System:
            Education, Regulation, Litigation and Legislation
    CHRISTOPHER BARDEN, J.D., Ph.D. (Introduced by Robert Koscielny)
  Closing Remarks
    PAMELA P. FREYD, Ph.D.  (Introduced by Peter Freyd, Ph.D.)

COST (includes shipping)
  Members          $12.00 per tape    $40.00 for series
  Non-Members      $15.00 per tape    $50.00 for series

              Order form at end of this e-mail edition.

                   F R O M   O U R   R E A D E R S
                           Therapy Threats
While I know you are familiar with all the methods that therapists use
to create and maintain false memories, I want you to know that my
therapist took this much further. As therapy progressed, whenever I
disagreed with his insistence that I attend group sessions, he
threatened to involve my husband and hospitalize me or go to my
employer. If I tried to visit my parents without his permission, he
said he would get a mental health warrant and detain me. While he
talked about protecting my confidentiality, he reiterated his
obligation to prevent me from harming myself. He repeatedly spoke with
my daughter's therapist, always with the concept of "working together"
but I later saw this as a way to reinforce all the falsehoods. He told
me that if I didn't "work through the memories," my daughter could not
be helped and any harm she caused to herself or others would be my
responsibility. These threats kept me in a constant state of overt
cooperation with my therapist as I tried to sort out all my
conflicting ideas internally. I didn't feel free to terminate therapy
with him.
                                                        A Retractor
                           Before and After
  My hero is not a famous man in the eyes of the world, but he is the
most important kind of man in this world. On the mature side of fifty,
he has lived beyond three wars, a major economic depression, several
social revolutions and countless personal problems...
  The day-in, day-out process of going about our lives is not
glamourous. It typically does not bring with it fame and fortune. No
covers on Newsweek, nor millions in the bank has he. My hero has also
been a man of leadership. Yet he has learned, too, when it is best to
follow instead of lead. An army officer for twenty years, he was
drafted during the Korean conflict and then served twice in VietNam.
However it is the years between and since these two wars that I find
heroic. War is not a time for heroics, it is a time for survival. The
heroism comes in working to keep us out of war.
  Most of all, though, I admire my hero for his attitude toward life.
He has never lost his optimism nor his integrity. To be a moral man in
an immoral time takes a courage above all other bravery. There is a
simple beauty in a person who will stand up for what he believes in. I
do happen to love my father very much, and I think he is a truly great

To  Mr. "T Father"
  You have some nerve calling this house on Father's Day of all days.
When were you ever a father to me? ... I will no long permit you to
hurt me in any way. Therefore I will be setting the following limits
on your outrageous behavior until you are ready to admit your guilt
and apologize. I will not allow you to communicate with anyone in
this household. Any letters you send will be thrown away unopened. If
you call, we will hang up immediately...

Dear Mom,
  Not only have I lost a father, he is trying to make sure I lose the
support of my entire extended family. He molested me for at least 13
years. My memories start when he left for Viet-Nam. Whether he started
earlier, I simply don't know...He abused me in every imaginable way
and some ways you would never imagine...He got me pregnant and
secretly took me to the doctor...
                         Nothing has Changed
Nothing has changed with our daughter who has accused us, but we hear
she is doing very well with her career - family - husband, etc. We
are fortunate that the other three children are wonderful to us --
which we appreciate. We are especially thankful about the youngest one
as she did not want to have much to do with us for the first two or
three years after this happened. Now and for the last two years she
has been like her old self, just like the daughter she always was. So
we feel very grateful -- even though we still miss our accusing
daughter. We feel that people do get used to things in time no matter
how terrible it was for so long. I would never want to go through that
  I sometimes wonder if maybe our accusing daughter now wonders if she
made a mistake but since things are going well for her now that she
doesn't want to take a chance of upsetting anything. I wonder if any
other parents feel this could be a factor. I still send birthday and
Christmas gifts to her and our grandchildren and I write notes once in
a while but I don't get anything back.
                                                        A Mom

                     B U L L E T I N    B O A R D
  (MO) = monthly; (bi-MO) = bi-monthly; (*) = see State Meetings list

                           *STATE MEETINGS*
             Call persons listed for info & registration
                      Saturday, May 3, @ 9:00 am
                Fort Snelling Officers Club, St. Paul
                      Dan & Joan (612) 631-2247
                     Saturday, May 3, @ 10:00 am
                     Colonial Park Hotel, Helena
                      Lee & Avone (406) 443-3189
                     Saturday, May 10, @ 1:30 pm
                     Speaker: Pamela Freyd, Ph.D.
                          Pat (416) 445-1995
                          June 16 & 17, 1997
                      Speaker: Elizabeth Loftus
                    Bar Ilan University, Ramat Gan
                Prof. Israel Nachshon (972) 3-635-0995

Contacts & Meetings:

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        Gideon (415) 389-0254 or
        Charles 984-6626(am); 435-9618(pm)
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        Judy (510) 254-2605
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        Jack & Pat (408) 425-1430
        3rd Sat. (bi-MO) @10am
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        Carole (805) 967-8058
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        Dee (619) 941-0630
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        Art (303) 572-0407
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        Earl (203) 329-8365 or
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  Rest of Illinois
        Bryant & Lynn (309) 674-2767
  Indiana Friends of FMS
        Nickie (317) 471-0922; ((fax) 317) 334-9839
        Pat (219) 482-2847
  Des Moines - 2nd Sat. (MO) @11:30 am Lunch
        Betty & Gayle (515) 270-6976
  Kansas City
        Leslie (913) 235-0602 or
        Pat (913) 738-4840
        Jan (816) 931-1340
        Dixie (606) 356-9309
  Louisville- Last Sun. (MO) @ 2pm
        Bob (502) 957-2378
        Francine (318) 457-2022
        Irvine & Arlene (207) 942-8473
  Freeport -  4th Sun. (MO)
        Carolyn  (207) 364-8891
   Ellicot City Area
        Margie (410) 750-8694
        Ron (508) 250-9756
  Grand Rapids Area-Jenison - 1st Mon. (MO)
        Bill & Marge (616) 383-0382
  Greater Detroit Area - 3rd Sun. (MO)
        Nancy (810) 642-8077
        Terry & Collette (507) 642-3630
        Dan & Joan (612) 631-2247
  Kansas City  -  2nd Sun. (MO)
        Leslie (913) 235-0602 or Pat 738-4840
        Jan (816) 931-1340
  St. Louis Area  -  3rd Sun. (MO)
        Karen (314) 432-8789
        Mae (314) 837-1976
    Retractors group also forming
  Springfield - 4th Sat. (MO) @12:30pm
        Dorothy & Pete (417) 882-1821
        Howard (417) 865-6097
        John (352) 750-5446
        Lee & Avone (406) 443-3189
  See Wayne, PA
  Albuquerque  - 1st  Sat. (MO) @1 pm
  Southwest Room -Presbyterian Hospital
        Maggie (505) 662-7521 (after 6:30 pm)
        or Martha 624-0225
  Westchester, Rockland, etc. - (bi-MO)
        Barbara (914) 761-3627
  Upstate/Albany Area  - (bi-MO)
        Elaine (518) 399-5749
  Western/Rochester Area -  (bi-MO)
        George & Eileen (716) 586-7942
  Oklahoma City
        Len (405) 364-4063
        Dee (405) 942-0531
        HJ (405) 755-3816
        Rosemary (405) 439-2459
        Paul & Betty (717) 691-7660
        Rick & Renee (412) 563-5616
        John (717) 278-2040
  Wayne (includes S. NJ) - 2nd Sat. @1pm
        Jim & Jo (610) 783-0396
  Wed. (MO) @1pm
        Kate (615) 665-1160
TEXAS -  Houston
        Jo or Beverly (713) 464-8970
        Keith (801) 467-0669
        (bi-MO) Judith (802) 229-5154
        Sue (703) 273-2343
        Pat (304) 291-6448
        Katie & Leo (414) 476-0285
        Susanne & John (608) 427-3686

  Vancouver & Mainland - Last Sat. (MO) @ 1- 4pm
        Ruth (604) 925-1539
  Victoria & Vancouver Island - 3rd Tues. (MO) @7:30pm
        John (250) 721-3219 (note new area code)
        Joan (204) 284-0118
  London -2nd Sun (bi-MO)
        Adriaan (519) 471-6338
        Eileen (613) 836-3294
  Toronto /N. York
        Pat (416) 444-9078
        Ethel (705) 924-2546
        Ken & Marina (905) 637-6030
        Paula (705) 692-0600
        Alain (514) 335-0863
  St. Andre Est.
        Mavis (514) 537-8187
        Irene (03) 9740 6930
  FMS ASSOCIATION fax-(972) 2-259282 or
  Task Force FMS of Werkgroep Fictieve Herinneringen
        Anna (31) 20-693-5692
        Colleen (09) 416-7443
        Ake Moller FAX (48) 431-217-90
  The British False Memory Society
        Roger Scotford (44) 1225 868-682
              Deadline for the June Newsletter is May 16
      Meeting notices MUST be in writing and should be sent no 
      later than 2 months prior to meeting. You must be a State 
      Contact or GroupLeader to post notices in this section.

|          Do you have access to e-mail?  Send a message to          |
|                                         |
| if  you wish to receive electronic versions of this newsletter and |
| notices of radio and television  broadcasts  about  FMS.  All  the |
| message need say is "add to the FMS-News". You'll also learn about |
| joining  the  FMS-Research list  (it distributes reseach materials |
| such as news stories, court decisions and research  articles).  It |
| would be useful, but not necessary, if you add your full name (all |
| addresses and names will remain strictly confidential).            |
For   this   e-mail   edition   of   the  FMSF  Newsletter  thanks  to 
the    Penn   Urology   Department,    Dr.  Alan   Wein,    all    the 
Weinie   Docs   and   all   the   other   folks   on   Silverstein 11.
  The False Memory Syndrome Foundation is a qualified 501(c)3 corpora-
tion  with  its  principal offices in Philadelphia and governed by its 
Board of Directors.  While it encourages participation by its  members
in  its  activities,  it must be understood that the Foundation has no 
affiliates and that no other organization or person is  authorized  to
speak for the Foundation without the prior written approval of the Ex-
ecutive Director. All membership dues and contributions to the Founda-
tion must be forwarded to the Foundation for its disposition.

Pamela Freyd, Ph.D.,  Executive Director

FMSF Scientific and Professional  Advisory Board,         May 1, 1997:
AARON T. BECK, M.D., D.M.S., University of Pennsylvania, Philadelphia,
PA;  TERENCE W.  CAMPBELL,  Ph.D.,  Clinical and Forensic  Psychology,
Sterling Heights,  MI; ROSALIND CARTWRIGHT,  Ph.D., Rush  Presbyterian
St. Lukes Medical Center, Chicago, IL; JEAN CHAPMAN, Ph.D., University
of   Wisconsin, Madison,  WI;    LOREN CHAPMAN,  Ph.D.,  University of
Wisconsin, Madison, WI;    FREDERICK C.  CREWS,   Ph.D., University of
California, Berkeley,   CA; ROBYN M.    DAWES,  Ph.D., Carnegie Mellon
University,  Pittsburgh,  PA; DAVID F.   DINGES,  Ph.D., University of
Pennsylvania, Philadelphia, PA; HENRY C.   ELLIS, Ph.D., University of
New Mexico, Albuquerque, NM; GEORGE K. GANAWAY, M.D., Emory University
of Medicine, Atlanta,  GA; MARTIN GARDNER, Author,  Hendersonville, NC
ROCHEL GELMAN, Ph.D., University of California, Los Angeles, CA; HENRY
GLEITMAN, Ph.D., University   of Pennsylvania, Philadelphia,  PA; LILA
GLEITMAN, Ph.D., University of Pennsylvania, Philadelphia, PA; RICHARD
GREEN, M.D., J.D., Charing Cross  Hospital, London; DAVID A. HALPERIN,
M.D., Mount Sinai School  of Medicine, New  York, NY; ERNEST  HILGARD,
Ph.D., Stanford  University, Palo Alto, CA;   JOHN HOCHMAN, M.D., UCLA
Medical School, Los Angeles, CA; DAVID S. HOLMES, Ph.D., University of
Kansas, Lawrence, KS; PHILIP  S.  HOLZMAN, Ph.D., Harvard  University,
Cambridge,   MA; ROBERT A.  KARLIN,  Ph.D.   , Rutgers University, New
Brunswick,  NJ;   HAROLD  LIEF,  M.D.,  University    of Pennsylvania,
Philadelphia, PA; ELIZABETH  LOFTUS, Ph.D., University  of Washington,
Seattle,   WA; SUSAN L.   McELROY,  M.D.   , University of Cincinnati,
Cincinnati,   OH;  PAUL    McHUGH,  M.D.,   Johns  Hopkins University,
Baltimore, MD;  HAROLD  MERSKEY, D.M., University  of Western Ontario,
London, Canada;  SPENCER  HARRIS  MORFIT, Author, Boxboro,   MA; ULRIC
NEISSER, Ph.D.,  Emory University, Atlanta,  GA; RICHARD OFSHE, Ph.D.,
University  of  California, Berkeley,  CA;   EMILY CAROTA ORNE,  B.A.,
University  of Pennsylvania,   Philadelphia, PA;  MARTIN  ORNE,  M.D.,
Ph.D., University  of Pennsylvania,  Philadelphia, PA; LOREN PANKRATZ,
Ph.D.,   Oregon  Health Sciences  University,  Portland,  OR; CAMPBELL
PERRY,  Ph.D.,  Concordia   University, Montreal,  Canada;  MICHAEL A.
PERSINGER, Ph.D.,  Laurentian University,  Ontario, Canada;  AUGUST T.
PIPER, Jr.,   M.D., Seattle, WA;  HARRISON   POPE, Jr.,  M.D., Harvard
Medical  School,  Boston,  MA;  JAMES   RANDI,  Author and   Magician,
Plantation,   FL; HENRY L.    ROEDIGER,  III, Ph.D.  ,Rice University,
Houston,  TX; CAROLYN  SAARI, Ph.D., Loyola   University, Chicago, IL;
THEODORE   SARBIN, Ph.D., University of    California, Santa Cruz, CA;
THOMAS A.  SEBEOK, Ph.D., Indiana University, Bloomington, IN; MICHAEL
A.    SIMPSON,  M.R.C.S.,   L.R.C.P.,   M.R.C,   D.O.M., Center    for
Psychosocial &   Traumatic Stress,  Pretoria, South   Africa; MARGARET
SINGER, Ph.D., University of California, Berkeley, CA; RALPH SLOVENKO,
J.D.,  Ph.D., Wayne State University   Law School, Detroit, MI; DONALD
SPENCE, Ph.D.,  Robert Wood  Johnson  Medical Center,  Piscataway, NJ;
JEFFREY VICTOR,  Ph.D.,  Jamestown Community  College, Jamestown,  NY;
HOLLIDA   WAKEFIELD,  M.A.,   Institute   of Psychological  Therapies,
Northfield, MN; CHARLES A. WEAVER, III, Ph.D. Baylor University, Waco,

   Y E A R L Y   FMSF   M E M B E R S H I P   I N F O R M A T I O N
Professional - Includes Newsletter       $125_______

Family - Includes Newsletter             $100_______

                       Additional Contribution:_____________


___VISA:  Card: #________-________-________-________ exp. date ___/___

___MASTER CARD: #________-________-________-________ exp. date ___/___

___Check or Money Order: Payable to FMS FOUNDATION IN U.S. DOLLARS.



Street Address or P.O.Box

City                                 State         Zip+4

Telephone                           FAX

              V I D E O   T A P E   O R D E R   F O R M
      M E M O R Y   A N D   R E A L I T Y:   N E X T   S T E P S

Mail Order To:
  FMSF Video
  Rt. 1 Box 510
  Burkeville, TX 75932

                                   DATE:   /   /

Ordered By:                        Ship to:

Please type or print information:
| QUANT- |  #  |            DESCRIPTION             | UNIT  | AMOUNT |
|  ITY   |     |                                    | PRICE |        |
|        | 222 | Welcome, Making a Difference,      |       |        |
|        |     |  What We Still Need to Know        |       |        |
|        | 223 | The Foundation as Friend of the    |       |        |
|        |     |  Court, Families and Courts, Panel |       |        |
|        | 224 | Helping Families is to Help        |       |        |
|        |     |  Everyone, Family Panel            |       |        |
|        | 225 | Reforming the Mental Health        |       |        |
|        |     |  System, Closing Remarks           |       |        |
|        | Set | Set includes one of                |       |        |
|        |     |   (222, 223, 224, 225)             |       |        |
                                                   SUBTOTAL |        |
                                                            |        |
                                    ADDITIONAL CONTRIBUTION |        |
                                                            |        |
                                                  TOTAL DUE |        |
                                                            |        |

Cost of tapes:
  FMSF Member - Single Tape  $12.00, Set $40.00
   Non-member - Single Tape  $15.00, Set $50.00

    Price includes shipping - allow two to thee weeks for delivery

The video tapes, which were not recorded by FMS Video, have some flaws
that could not be corrected by editing. You may experience problems
such as short periods where their is no sound and the camera is out of
focus or did not tape the speaker. Some of the slides of the presenters
were not available for dubbing.

Made all checks payable to FMS Foundation. If you have any questions
concerning this order, call Benton, 409-565-4480.

The tax deductible portion of your contribution is the excess of goods
and services provided.

                     THANK YOU FOR YOUR INTEREST