Creating Repressed Memories: A Case Example

Terence W. Campbell

On a gray, overcast day in November of 1994, Jim Bauer¹ faced the most excruciating ordeal he had ever encountered over the course of his life. Criminal charges alleging he had sexually abused his first-born daughter were being brought to trial in Michigan's Allegan County. In particular, the prosecution claimed that Terri Richards (30 years of age and Mr. Bauer's oldest child) had repressed her memories of the abuse she supposedly suffered as a child until she recovered them in psychotherapy. Mr. Bauer, however, emphatically denied these charges from the outset, pleading not guilty and demanding a jury trial.

Inpatient Treatment History

The events leading to this situation began in August of 1988 when Ms. Richards was admitted to a psychiatric inpatient facility. At time of her admission, Ms. Richards was married and already the mother of four children, with the youngest child having been born in February of 1988. Hospital records indicated that Ms. Richards:

. . . has struggled with depression with withdrawal, irritability, remaining in bed but with sleep problems at night, feeling tired, no energy, increasing tearfulness, much more impatient and irresponsible with her children, anorexia with a 15 pound weight loss and lack of ambition. . . . An added stressor has been a motor vehicle accident in December [1987] in which her husband was seriously injured and had suffered a head injury . . . She had a brief postpartum depression after her third child. At that time she also felt suicidal with reduced impulse control and received outpatient therapy. . . . In individual sessions the patient worked on issues surrounding past history of sexual acting out and impulsivity to deal with difficult feelings as well as revealing a past history of sexual abuse at the hands of a cousin and grandfather. She was also raped by two men when 19 years of age and was unable to identify who these men were.

The known issues precipitating Ms. Richards' admission to an inpatient psychiatric facility in August of 1988 completely accounted for her condition. Her clinical condition was consistent with an individual who felt overwhelmed by the responsibilities of caring for her fourth-born child, while anticipating that her husband could not assist her very well. Additionally, as a first-born child, Ms. Richards likely found it difficult to ask for help and assistance. First-born individuals tend to be quite independent and autonomous, preferring to rely on themselves to solve their problems. Moreover, Ms. Richards was clearly willing to report previous episodes of sexual abuse. This consideration indicates that if her father had sexually abused her in the past, she would have reported it. Consequently, one need not have hypothesized any repressed memories of sexual abuse to account for her condition in August of 1988.

09-09-88: Discharge diagnosis from inpatient facility:

Axis I: 296.33 Major Depression, Recurrent, Severe, With Melancholia But Without Psychosis.

Axis II: No diagnosis on Axis II, but evidence of passive-aggressive and borderline features.

9-19-88: On this date, Ms. Richards consulted with Ms. Smith, an MSW employed at an outpatient facility providing psychotherapy services. Ms. Smith completed a standardized form identifying the following problems with which Ms. Richards was contending:

1. Makes own plans but without considering the needs of other family members.

2. Seldom holds job, or attends some classes, or does limited housework.

3. Seldom able to get along with others without quarreling or being destructive, or is often alone.

4. Almost always feels nervous or depressed, or angry and bitter, or no emotions at all.

5. Only occasional recreational activities, or repeats the same activity over and over again.

6. Severe problems most of the time.

7. Negative attitude toward self most of the time.

Beyond this initial consultation, however, Ms. Richards did not undertake any course of treatment with Ms. Smith at this time. Her psychological condition continued to deteriorate and she was re-admitted to the previous inpatient facility in December of 1988. Hospital records at that time indicated:

12-01-88: [Ms. Richards] . . . reports that she was in her house with a scalpel blade, thinking about cutting her wrists . . . she has been becoming increasingly depressed with inability to attend to her duties as a housekeeper and, today, she was unable to care for her children's needs or to attend to her household duties . . . The patient admits to a history of sexual abuse from a paternal grandfather when she was 7 years old as well as from a 17-year-old cousin when she was 12 years old. She also admits to being raped by an unknown person when she was 21 years old.

Over the course of this hospitalization. Ms. Richards:

. . . explored the anger she had toward her family for not protecting her from her grandfather and was able to move beyond that anger to deal more effectively with the incest experience.

Unfortunately, Ms. Richards' therapist apparently never considered the necessity of involving her parents in her treatment to increase her feelings of trust in them. Had the therapist sought to enlist the support of Ms. Richards' parents on her behalf at this time, the outrageous allegations in this criminal case probably would have never occurred.

01-13-89: Discharge diagnosis from inpatient facility:

Axis I: 309.00 Adjustment Disorder With Depressed Mood.

Axis II: 301.83 Borderline Personality Disorder.

Outpatient Treatment

01-23-89: Ms. Richards initiated psychotherapeutic treatment with Ms. Smith, the MSW therapist she had previously consulted with on a one-time basis in September of 1988. Ms. Smith's treatment plan indicated, among other considerations, that Ms. Richards: ". . . was sexually abused by her paternal grandfather and a male cousin. There may have been other sexual abuses in her past as well." The statement, "other sexual abuses in her past," may have been referring to the previously cited rape suffered by Ms. Richards at age 19 or 21, or it may have indicated Ms. Smith's eagerness to venture off into a fishing expedition looking for supposedly repressed memories of sexual abuse.

Ms. Smith specified the following treatment goals for Ms. Richards:

1. To identify the impact of sexual abuse on her life.

2. To identify the issues within her marriage that need to be resolved.

3. To promote and increase self-esteem.

At best, these treatment goals were ill-defined, and at worst, they were irrelevant to Ms. Richards' psychological welfare. Rather than "identify the impact of sexual abuse on her life," Ms. Richards needed a well-defined course of action regarding what she was going to do about those issues in order to deal with them more effectively. Similarly, Ms. Richards also needed a well-defined course of action regarding what she could do to resolve problems in her marriage. In other words, considerations of what needed to be done as opposed to why the problems existed, would have been more responsive to Ms. Richards' welfare (Campbell, 1994a).

At this time, Ms. Smith formally undertook treatment with Ms. Richards, seeing her an average of twice a week. The following chronology cites the most relevant portions of Ms. Smith's treatment notes and identifies the specific problems with the treatment given.

01-23-89: [Ms. Richards] . . . Seen with husband Dave . . . Dave wants to be involved in all the therapy — I set limits. Terri to be seen individually 2 times a week. Dave to attend individual [therapy] with Kate C. Occasional joint sessions to keep the two connected and marital sessions "down the road." Terri resistant to Dave knowing everything.

Disregarding Marital Issues

Despite the fact that Mr. Richards was genuinely committed to his wife's welfare and wanted to help her, Ms. Smith reduced him to a peripheral role in her treatment. Simultaneously, Ms. Smith appointed herself to a position of excessive significance in Ms. Richards' life. Nevertheless, Ms. Smith neglected to consider how she could resolve a two-person, marital conflict when her treatment focused primarily on only one of those two people (Ms. Richards).

01-31-89: Brought little notebook and read off thoughts and issues she'd thought of. Many acknowledged fears re: trusting me. Talked in depth about them and gave [her] permission to feel hesitant.

At this point, Ms. Richards found herself subjected to what is known as the "bait-and-switch" tactic in psychotherapy (Williams, 1985). She sought treatment to deal with the seven issues outlined September 19, 1988, but Ms. Smith "switched" her to examining how she felt about her therapist. In effect, Ms. Smith was telling Ms. Richards, "Before you can solve your problems, you must understand your relationship with me. Therefore, your relationship with me is more important than solving your problems."

02-06-89: Focused on relationship with Dave and feeling pressured by him into sex when she didn't want it. Explored what she connects to it — separates intimacy from sexuality and talk some about her affairs.

Obviously, Ms. Richards was contending with marital problems. But as a result of reducing Mr. Richards to a peripheral role in his wife's treatment, Ms. Smith was reduced to "talking about" these important marital issues. Without Mr. Richards regularly participating in treatment, Ms. Smith could not assist him and his wife with what they needed to do to reduce the frequency and intensity of their conflicts.

02-16-89: Focused on her resistance. Fears of my not liking her revealed. Able to acknowledge that she feels pressure building and is fearful of returning to the hospital. Explored some perceptual disturbances connected to trust. To write in notebook. Next session with Dave.

If Ms. Richards' fears of Ms. Smith not liking her had developed into a major issue, then Ms. Smith had allowed herself to become far too important to Ms. Richards. When therapists emerge as such central figures in the lives of their clients, they typically accomplish little more than to solicit the client's dependency (Campbell, 1994b).

Psychotherapists frequently acquire substantial prominence in the lives of their clients. For example, Tarragona and Orlinsky (1988) reported that more than 80% of the clients in their study experienced thoughts, feelings, memories, or images involving their therapist between sessions. These intersession experiences occurred most frequently when the clients found themselves contending with difficult situations or were feeling discouraged. Not surprisingly, then, Dashkovsky (1988) suggested that lonely and isolated clients may depend excessively on the therapeutic relationship and idealize the therapist as a result.

02-20-89: Dave and Terri [seen together] — focused on misunderstandings re: the other's perception. Structured a code signal to have each slow down and talk it thru. Also focused on Dave's sense of guilt for Terri's dissociating, gave permission for him to step back from that — redirected them to share frustration on the "same" team.

In this particular session, Ms. Smith responded effectively to Mr. and Ms. Richards. Her emphasis on sharing frustration — apparently as opposed to taking frustrations out on each other — was altogether appropriate. However, Ms. Smith neglected to maintain this focus over the future course of treatment for Ms. Richards.

Blame-and-Change Maneuvers

02-23-89: Focused on sexual contact. [Terri reported how] attempted massage with Dave and held high expectations for enjoying contact which were blocked. Refocused on how to limit expectations and try again. Also addressed how dynamics with Dave replicate family dynamics, particularly regarding being ordered about and her needs ignored.

In this session, Ms. Smith was suggesting that Ms. Richards grew up in a family where she "was ordered about" and "her needs ignored." This tactic is known as the "blame-and-change" maneuver in psychotherapy — suggesting to clients that treatment must "blame your family in order to change you" (Campbell, 1992a). Unfortunately, therapists regularly indict their clients' families in this manner despite never meeting the people whose character they irresponsibly assassinate.

03-06-89: Focused on sexuality — re: different behavior she exhibits with strangers and not with husband. Assigned exercise to connect with her own body with husband. Separates pleasure from intimacy.

Though Ms. Smith appeared well intended, her assigned exercise was ill-advised. Mr. Richards did not participate in this session, and as a result, he would not know how to appropriately respond as his wife carried out her assignment with him. In other words, Ms. Smith had undertaken a rather risky endeavor. She was engineering major changes in a two-person relationship, but only working regularly with one of them. As a result, she did not know how Mr. Richards was going to react to the changes she was creating.

03-20-89: Focused on her anger re my illness. Discussed abandonment issues from mother's frequent headaches differentiated that mother did not take care of her even when well. Terri projected I called in sick only to test her and she contemplated acting out by calling secretary and screaming. Also touched on changes in sexuality with David.

Ms. Smith had again resorted to more blame-and-change maneuvers, directing her indictments at Ms. Richards' mother. While preoccupied with blaming-and-changing, Ms. Smith merely touched on the more important issues related to Ms. Richards' relationship with her husband.

03-30-89: [Ms. Richards] Brought in photo album and teenage journal and letters. Looked at pictures — identified family members. Little reaction to grandfather. Picture not like she thought of him. Discussed seeing him in person. Some intimation of fear of memories — possibly father abused.

This is the first time that Ms. Smith's notes indicated any suggestion that Ms. Richards' father had sexually abused her. Entertaining this possibility obviously necessitated that Ms. Smith rely on conventional but erroneous assumptions regarding trauma and memory loss to account for Ms. Richards not previously disclosing this supposed abuse. In her preliminary examination testimony of June 2, 1994, Ms. Smith revealed the extent to which she uncritically endorsed ill-informed assumptions related to repression. While outlining her thinking about trauma and memory, she contended that, "If there has been a traumatic memory that has been suppressed as a defense mechanism of the psyche, then that usually stays suppressed until it reappears."

04-10-89: Ms. Smith completed a quarterly review of Ms. Richards' treatment on this date. This review indicated that she wanted to evaluate Ms. Richards "for possible MPD" (Multiple Personality Disorder).

Preoccupation with MPD

While considering a diagnosis of Multiple Personality Disorder for Ms. Richards, Ms. Smith blithely disregarded the substantial body of accumulated evidence demonstrating that MPD is frequently overdiagnosed (Aldridge-Morris, 1989; North, Ryall, Ricci, & Wetzel, 1993; Spanos, 1994). For example, it seems rather curious that a condition supposedly as common as MPD is not diagnosed by a majority of psychiatrists on both sides of the Atlantic (Fernando, 1991). Despite the considerable attention directed to MPD in the early 1900s in France, the diagnosis is rarely reported there now (Spanos, 1994). The diagnosis of MPD is also very rare in Great Britain (Fahy, 1988), Russia (Allison, 1991), and India (Adityhanjee & Khandelwal, 1989). A Japanese survey also failed to find so much as a single case of MPD (Takahashi, 1990). But most likely Ms. Smith was unaware of these cross-cultural data underscoring the extent to which the increasing frequency of diagnosed MPD in the United States and Canada amounts to a pseudo-epidemic.

05-24-89: Cried first — stated she missed me and talked about her panic last week. Also related she suspects her father sexually abused her — hard to admit. Also questioned her re time and loss of memories — she asked if I thought she was MPD — didn't rule out. She wants to pursue because very disturbed by dissociating.

Ms. Smith's willingness to blame Ms. Richards' parents has already been documented. When Ms. Richards' reported suspicions of her father having sexually abused her, these suspicions likely reflected Ms. Smith's influence. Without ever having seen Mr. Bauer on a first-hand basis, the relevant research (David & Baron, 1994; Prager & Cutler, 1990) demonstrates that Ms. Smith was predisposed to view him in more extreme terms. Furthermore, relying on second-hand information about others encourages observers to stereotype them in an exaggerated manner (Gilovich, 1987, 1991). Consequently, in addition to influencing how Ms. Richards viewed her father, Ms. Smith's influence was also ill-informed.

05-25-89: Focused on assessment regarding dissociation and MPD.

Ms. Smith's preoccupation with MPD issues increased the likelihood of her subjecting Ms. Richards to an iatrogenic disorder created via suggestibility (Aldridge-Morris, 1989; Spanos, 1994). In her determination to confirm her diagnostic impressions of MPD, Ms. Smith likely conveyed her expectations to Ms. Richards. As a result, Ms. Richards would have been motivated to comply with those expectations, and begin simulating the symptoms Ms. Smith expected to see.

06-12-89: Shared that she has more answers to the questions I asked on 5-25. More incidents in childhood and adolescence — being told she did things and she didn't remember — being called liar — told she had taken and passed exams and she thought she never did, etc.

Ms. Smith refers to questions she asked Ms. Richards on 5-25-89. However, an examination of Ms. Smith's notes for that date does not indicate her asking any questions or what they were. Therefore, this suggests that a great many things transpired in Ms. Smith's sessions that she never recorded in her notes. In fact, during her preliminary hearing testimony of February 9, 1994, Ms. Smith acknowledged that there is no way of knowing everything she said to Ms. Richards during their therapy sessions. At this same hearing, Ms. Smith further admitted that many events may have occurred in Ms. Richards' therapy that were never documented in her notes.

Inventing Memories

07-20-89: . . . Talked of memory of being a child and hiding in bathroom at campground all day. Mother found her and dragged back to campsite. Adult relatives sitting around fire, Terri wet her pants as she was pulled into the camp. Put to bed, but first her father grabbed her teddy bear and said she was too old for it, then threw it on the fire. The adults were silent. Terri remembered no further information.

Childhood memories such as these are notoriously unreliable, and more than anything else, this particular memory of Ms. Richards likely reflected the blame-and-change influences of Ms. Smith. The traditional analytic pursuit of insight has predisposed legions of therapists to lead their clients into detailed analyses of how their families supposedly betrayed them (Campbell, 1992b). Such therapists suggest that clients must understand the many effects of their family's alleged maltreatment in great depth and detail. In their determination to promote these kinds of insights, therapists can prime their dialogues with clients. Priming refers to influential discourse directing a target person's attention to a particular topic or frame of reference for interpreting information (Bower, 1981; 1986).

Priming effects activate specific cognitive schemas in target subjects influencing them to adopt a particular frame of reference for interpreting information (Erdley & D'Agostino, 1988; Herr, 1986; James, 1987). Therapists can exercise priming effects via leading questions, persistently examining particular topics, and resorting to slanted adjectives. In turn, the responses expected of clients — inventorying their supposed familial betrayals — receive greater therapist attention and corresponding reinforcement. Therefore, priming effects afford therapists the opportunity to lead clients into creating very distorted memories.

08-17-89: [On this date Ms. Smith interviewed Ms. Richards' three oldest children. When she asked Johnny, "what could I help fix for him?", Johnny replied, "Mom and Dad fighting." Sara's response to this question "was the same as Johnny's — Mom and Dad fighting. Maddy — same answer about fighting."]

In other words, after almost seven months of therapy at two sessions per week, Ms. Richards still found herself involved in frequent and intense disputes with her husband. This consideration corresponds to the extent to which Ms. Smith neglected to deal appropriately with the marital conflicts in this case. Rather than respond effectively to these issues, Ms. Smith was much more interested in pursuing a diagnosis of MPD for Ms. Richards. The relevant research (Franks et al.,1992), however, demonstrates that the acrimony and turmoil inundating Ms. Richards' marriage severely jeopardized her psychological welfare. Therefore, effective therapy for Ms. Richards would have identified these problems as treatment priorities.

09-11-89: Focused on family of origin and how to handle the negative reactions. Explained dynamics as we discussed. Again addressed need to identify with me.

Tyranny of the Past

Like so many therapists, especially those with an affinity for analytic thinking, Ms. Smith assumed that Ms. Richards' here-and-now psychological distress reflected the influences of traumatic events from her distant past. Despite the prevalence of therapeutic thinking embracing assumptions about "the tyranny of the past" (Dawes, 1994) — and its supposedly never-ending influence on the present — the relevant research supports neither this thinking nor its related assumptions. A comprehensive review of the relevant literature found only modest relationships between early childhood experience and later development (Scarr, Phillips, & McCartney, 1990). This review concurred with Kagan's (1979) position that life-span continuity does not imply developmental inevitability.

This note also raises questions about what "dynamics" Ms. Smith discussed. Was it at this point that Ms. Smith outlined her thinking regarding how Ms. Richards' father allegedly raped her and she then repressed it? Additionally, and perhaps even more importantly, Ms. Richards' "need to identify" with Ms. Smith created a situation wherein she was also excessively dependent on her, motivated to seek her approval, and therefore predisposed to report past memories consistent with her therapist's expectations.

09-14-89: Reviewed memories that plague her — all indicate lapses in memory and times. Difficult for her to accept it — scared to let others identify to me because it will "confirm" MPD.

Rather than uncover the "historical truths" of Ms. Richards' past, Ms. Smith more likely constructed "narrative truths" (Spence, 1992), and she was ill-informed enough to regard them as historically accurate. Therapists construct narrative truths by organizing the information that clients present into themes consistent with the therapist's theoretical orientation. These themes are then outlined for clients via the interpretations, summaries, and reflections of their therapist. In turn, clients respond to the therapist's influence by reporting new information that appears to verify the preliminary versions of narrative truth created from their previous dialogues.

Too often, however, the historical truths related to the presumed events of a client's developmental history reflect the effects of confirmatory bias, ". . . the tendency to seek supportive data for one's hypotheses and to underweight or disregard nonsupportive data" (Faust, 1989, p. 475 ). Confirmatory biases can lead therapists into limiting their questioning of clients to queries that can only confirm hypotheses such as formative trauma and/or parental betrayal, and simultaneously, they avoid questions that could elicit disconfirmatory responses (Arkes, 1981).

Related data, for example, demonstrate that attempting to determine whether an individual is an extrovert leads subjects into asking mostly one-sided questions — "What would you do if you wanted to liven up a party?" (Snyder & Swann, 1978). Similarly, then, assumptions about a client's presumed history of formative trauma and/or parental betrayal can increase the frequency of confirmatory questions directed at those issues — and asking enough confirmatory questions allows psychotherapists to conclude they have found the answers they were expecting.

09-20-89: [Ms. Richards] Very distant — indicated she's angry — "pissed," about my being sick. Relates this to constantly ill mother — can't rely on me, thinking of getting another therapist, etc. Indicated she has power to make a choice — that I do not get sick to avoid her, etc. Calm by end — able to acknowledge fear of dependency with me.

In fact, Ms. Smith had canceled sessions with Ms. Richards on 2-9-89, 6-l-89, 8-8-89, 9-6-89, and 9-18-89. Four of the five cancellations occurred within approximately three months of each other. Given these considerations, Ms. Richards' anger was altogether understandable. But Ms. Smith suggested that Ms. Richards' anger really originated with her mother who supposedly was "constantly ill." Rather than take responsibility for her own behavior and acknowledge an unusual frequency of cancellations, Ms. Smith found a way to blame someone else — Ms. Richards' mother!

09-28-89: (1:00-2:00 p.m.) [Ms. Smith saw Mr. and Ms. Richards along with his parents, Bill and Ila Richards, on this date.] Gave general information regarding MPD. Stressed need for privacy for Terri's work — Ila picked up on this as it related to David telling them things — to follow later. Both Ila and Bill expressed support, Terri expressed thanks.

Despite the fact that Ms. Smith used this session for a nonexistent problem, MPD, the reactions of Ms. Richards' husband and in-laws were quite important. Quite obviously, Ms. Richards' mother-in-law and father-in-law responded to her in an exceedingly supportive manner. A competent therapist would have capitalized on this kind of support long before now, and used that support to address the goals outlined on 9-19-88, which Ms. Smith appeared to have completely forgotten.

Serving the Therapist's Needs

09-28-89: (3:00-4:00 p.m.). [Ms. Smith then saw Ms. Richards by herself after the family session.] Terri feels relieved. Indicated approval of everything I said, especially in addressing her privacy. Dave and her to talk later about this.

Approximately two hours prior to this session, Ms. Richards' in-laws demonstrated an impressive level of support and understanding on her behalf. Rather than address and comment upon this critically important issue, Ms. Smith preferred to proudly record how Ms. Richards "indicated approval of everything I said." This self-serving report raises the question of whose needs was Ms. Smith addressing in this therapy — Ms. Richards' or her own?

11-06-89: Mother has called. Terri freezes, mother demands and Terri can't speak. She's to decide with David whether they want their children to see them at Xmas or not, then set limits.

Ms. Smith reports that "Terri freezes, mother demands, and Terri can't speak." Persuasive as this may seem, it also raises other difficult questions — Ms. Smith is reporting the dynamics of a two-person relationship she never saw. Without directly observing the interactions between Ms. Richards and her mother, Ms. Smith was indulging in inappropriate speculation — speculation guided by her assumptions related to blame-and-change maneuvers. Even more egregious was Ms. Smith's willingness to alienate Ms. Richards, and her own children, from her parents. This kind of alienation can create enormous problems, leading to despair of suicidal proportions. The French Sociologist Durkheim first discussed these issues in 1897; apparently, Ms. Smith was still unfamiliar with this well-established thinking in 1989.

01-08-90: Got thru holidays OK. Had list to start — some confrontation with mother in dreams — labeled herself as psychic then discounted. Started to reveal memory of hiding under porch, being quiet and mom on porch calling her and crying. Stopped self — confronted. Also confronted re lost memories and looking for others [illegible]

It is important to note that Ms. Smith did not specify exactly what she confronted Ms. Richards about, and in particular, what memories she confronted her about. It is quite possible that at this time Ms. Smith was confronting Ms. Richards about memories she thought Ms. Richards should be recalling. If so, Ms. Smith was encouraging Ms. Richards to speculate about childhood events.

Speculative exchanges between therapists and clients, however, readily lead to overconfidence. The data demonstrate that conjecture addressing why some event might have occurred leaves people more confident that the event did occur despite the unavailability of any evidence to support such a conclusion (Anderson, Lepper, & Ross, 1980). Furthermore these speculative exchanges frequently respond to the effects of leveling and sharpening (Gilovich, 1987, 1991). Both therapist and client can sharpen their impressions related to what seems significant about the client's past, and simultaneously they level what seems less than significant. Often, however, the processes of sharpening and leveling respond more to the theoretical convictions of the therapist than reflecting an accurate assessment of the client. Nevertheless, the consensus shared by therapist and client can create unwarranted confidence in their conclusions.

01-10-90: [On this date, Ms. Smith saw Mr. and Ms. Richards together.] David concerned regarding Terri's anxious state suggesting hospital. I reinforce her work as appropriate. Her father called yesterday and she dissociated — later angry and explosive and Dave confused.

This note raises the question regarding exactly what "work" did Ms. Smith reinforce as "appropriate" — supposed memory recovery work? Moreover, how did Ms. Smith know that Ms. Richards dissociated when she spoke to her father? To belabor the obvious, Ms. Smith did not directly observe how Ms. Richards reacted to her father's phone call.

02-06-90: Focused on anger re my absence. Reviewed pros and cons of any close relationships — set limits re anger — repeated reassurances that I'm not trying to dump her. She wanted me to make decision re: her staying or not — I refused. Stressed need to resolve transference issues re: mother's sickness.

In a little more than one year of treatment, Ms. Smith has now canceled a total of seven sessions: 2-9-89, 6-1-89, 8-8-89, 9-6-89, 9-18-89, 12-5-89, and 2-5-90. Ms. Richards' growing intolerance of these cancellations was altogether understandable. But Ms. Smith again attempted to avoid responsibility for her own actions, instead blaming Ms. Richards' mother for how Ms. Richards reacted.

02-15-90: [On this date, Ms. Smith saw Mr. and Ms. Richards together.] . . . also addressed David's push for anti-anxiety medication, he's judging Terri's therapy.

In this session, the basis of Ms. Smith's attitude regarding Mr. Richards becomes more evident. In Ms. Smith's opinion, Mr. Richards was "judging" her work, and suggesting that her efforts with his wife were not going well. Apparently, Ms. Smith does not deal well with clients — or their families — who question her endeavors.

Imagination Contaminating Memory

03-01-90: Started with memory of white garage and green door, fears she set fire to it — feels fear. Blocked going further. Discussed some of the process to recovery of memories. We planned to meet Monday at the house to explore possible feelings.

At this point, and likely earlier, Ms. Smith created memory problems for Ms. Richards involving source monitoring failures. Research on source monitoring demonstrates that what people remember and the source of a particular memory exist independent of each other (Johnson, Hashtroudi, & Lindsay, 1993). For example, 6-year-old children find it difficult to accurately discriminate between actual events and imagined events (Foley & Johnson, 1985). Specifically, these children confused memories for what they actually did compared to what they imagined doing (e.g., "Did you really touch your nose, or did you just imagine yourself touching your nose?"). Similarly, adults find it difficult to accurately remember what another person actually said, versus what they imagined the other person saying (Johnson, Foley, & Leach, l988).

Therapists who are determined to obtain evidence of formative trauma and/or parental betrayal from their clients can create difficult source monitoring problems for them. In between therapy sessions, clients think a great deal about what their therapist said — or what the clients think the therapist said. As a result, these clients can become confused about what they heard, compared to what they think they heard.

Even more importantly, clients can become confused about what someone in their family actually did versus what a therapist suggested that the family member may have done. When clients are trying to cooperate with their therapist, they can begin reporting imaginary events, but consider them legitimate instances of memory because of source monitoring failures.

Clients whose memories are distorted by source monitoring problems will more readily recall events suggested by their therapist but mistakenly attribute the source of their "memories" to their own past experiences. Overwhelmed and discouraged in response to learning how their families supposedly betrayed them, clients recall more and more anecdotes consistent with their family's alleged "toxicity" as a result of mood-congruent memory effects (Baker & Guttfruend, 1993; Singer & Salovey, 1988). Depression, for example, increases the probability of people remembering their parents as rejecting and relying on negative controls, but this effect promptly dissipates as the level of depression diminishes (Lewinsohn & Rosenbaum, 1987).

Mutually motivated to reduce the ambiguity surrounding the client's past, both therapist and client may attribute unwarranted significance to what is actually conjecture in the service of rumor formation (Allport & Postman, 1947; Rosnow, 1991). Through a process of successive approximations, the speculative exchanges between clients and therapists can converge into a commonly shared conviction (Bonanno, 1990) — the client suffered episodes of formative trauma and/or parental betrayal which remained repressed until uncovered by the therapist. Once they construct conclusions such as these, therapists and clients can cling tenaciously to them insisting, "We agree, therefore we must be right" (Campbell, 1992c).

03-05-90: Met at childhood home. Retraced memories she has — fear occurred during some memories — acknowledged blocking. Biggest discovery for self was how small the house actually was — could her mother really have not heard the abuse? More details regarding the bondage in the dining room.

By this time, then, Ms. Smith had persuaded Ms. Richards that as a child her father had sexually abused her. Nevertheless, Ms. Smith's own notes disclose how unreliable retrospective memory is — Ms. Richards childhood home was much smaller than she remembered it. Even more importantly, Ms. Richards expressed her doubts about whether her father could have abused her without her mother hearing it. Apparently, however, Ms. Smith chose not to respect her client's doubts.

03-22-90: Discussed fears of judgment in family. Feelings and memories pushing thru, not quite sure what to do.

Any feelings and memories that were supposedly "pushing through" at this time likely did so in response to Ms. Smith's influence. In view of the extent to which suggestive questions can distort memory via source monitoring failures, the degree of Ms. Smith's influence should not be underestimated. For example, assume that you are asked — "The last time you were at the airport, did you see the team of three elephants pulling the passenger jet down the runway with two clowns dancing on each wing?" Most people respond to this question by vividly imagining three massive, gray mammals lumbering down a runway, laboring against the weight of the plane, with two outrageously costumed figures prancing vigorously about each of its wings. Despite our facility for imagining this scene, however, it is unlikely that anyone would actually think they remembered it. The scene itself is so implausible that it immediately provokes rejection as a legitimate memory.

But on the other hand assume that a therapist asks questions such as (1) "Maybe there was a time when your father looked at you in a seductive way?"; (2) "Possibly he spoke to you in a suggestive manner?"; and/or (3) "Might he have touched your arm or face rather sensuously?" Each of these questions also arouses corresponding imagery and clients can confuse this imagery with emerging memories because they consider these scenes as plausible events. Therefore, directing enough questions at clients about subjective circumstances can easily lead them into both revising and distorting memories of benign events and creating other memories for which there is no basis whatsoever in fact.

While testifying at a preliminary hearing seeking an indictment against Mr. Bauer, Ms. Smith vehemently denied ever having influenced Ms. Richards' memory. In particular, she claimed:

I'm not active in that recovering of memory process . . . memories do not come back before [the] psyche is ready to handle it [sic] . . . So I am not active with my clients in terms of trying to make them remember.

Without having recorded her sessions with Ms. Richards, Ms. Smith's claims regarding how active she was in treatment are not supported by the relevant data. In fact, psychotherapists do not accurately recall how they influence clients (Chevron & Rounsaville, 1983; Muslin, Thurnblad, & Meschel, 1981). They are characteristically oblivious to the influences they exercise in therapy because instead of monitoring their own behavior they focus their attention on what the client is saying (Xenakis, Hoyt, Marmar, & Horowitz, 1983).

Conclusion

Ms. Richards remained in treatment with Ms. Smith throughout 1990 and into mid-1991. During the first preliminary examination related to the criminal charges against her father, Ms. Richards claimed she had no clear memories of him allegedly raping her until the spring of 1991 when she disclosed these supposed events to Ms. Smith. Ms. Richards' testimony, combined with that of Ms. Smith, resulted in her father undergoing trial for numerous counts of First Degree Criminal Sexual Contact, a life sentence felony in the State of Michigan.

Expert testimony on behalf of Mr. Bauer emphasized, among many issues, four points (Campbell, 1995):

1. There is no accumulated body of evidence demonstrating that trauma — such as childhood sexual abuse — motivates people to repress events associated with that trauma.

2. The reliability of studies suggesting that childhood sexual abuse leads to repression rapidly falls apart when examined closely. These studies characteristically overlook considerations such as normal childhood amnesia, everyday forgetting, and the influences of therapists.

3. Retrospective reports recalling subjective psychological states and related family dynamics are inherently unreliable.

4. Psychotherapy frequently results in clients and therapists constructing memories that involve more fiction than fact. Indeed, the biases of too many therapists lead them into profoundly distorting the memories of their clients.

After the presentation of closing arguments, the jury began its deliberations. Disinclined to engage in any rush to judgment, the panel of 12 jurors deliberated almost three hours before it reached its unanimous verdict — Not Guilty. Relieved as Mr. and Mrs. Bauer were, this verdict has not eliminated the continuing pain and emptiness they feel for their first-born child who still alienates herself from them.

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