Psychology of Consciousness: Theory, Research, and Practice

2015, Vol. 2, No. 2, 153169

2015 American Psychological Association

2326-5523/15/$12.00 http://dx.doi.org/10.1037/cns0000044

False Memories in Therapy and Hypnosis Before 1980

Lawrence Patihis and Helena J. Younes Burton

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University of California, Irvine

To determine the extent to which false memories occurred in therapy or hypnosis
before the Memory Wars controversy, we examined the early history of the phenomenon before 1980. We found evidence of perception distortion from the early
hypnotists and mesmerizers, but only circumstantial evidence of memory distortion.
The earliest firm evidence of false memories we found was during Bernheims hypnosis
in 1884. After this date, we found additional evidence of varying strength, from
memories of infancy that may be false, to episodic memories of past lives and alien
abductions that are certainly false. Other strong evidence included 19th century evidence of hypnotists deliberately distorting memory, and their acknowledgment of doing
so. We discuss how this evidence is consistent with recent false memory research. We
suggest that without knowledge of the history of false memory formation, clinicians
could be vulnerable to repeating the mistakes of the past.
Keywords: autobiographical memory, false memory, hypnosis, mesmerism, therapy

Those who cannot remember the past are condemned

to repeat it.
George Santayana (1905, p. 284)

In the light of the heated debate about repressed

memory in the 1990s (sometimes called the
memory wars; see Crews, 1995), recent false
memory and reconsolidation research (e.g., Patihis
et al., 2013; Nader, Schafe, & Le Doux, 2000),
and the realization that some therapies in the
1980s and 1990s produced false memories, we
address the question of whether there is evidence for false memories in therapy or hypnosis
before the 1980s. Although others have previ-

This article was published Online First March 30, 2015.

Lawrence Patihis and Helena J. Younes Burton, Department of Psychology and Social Behavior, University of
California, Irvine.
Lawrence Patihis is now at Department of Psychology,
University of Southern Mississippi.
Many thanks to suggestions and comments on this topic
and article from scholars with expertise of the history of
therapy and hypnosis, including Steven Lynn, John Kihlstrom, Jean-Roch Laurence, Frederick Crews, Harald Merckelbach, and Edward Shorter. Thanks to Elizabeth Loftus
for her support of our Undergraduate Research Opportunities Program Fellowship project at UC Irvine. This research
was also supported in part by the National Science Foundation Graduate Research Fellowship Program.
Correspondence concerning this article should be addressed
to Lawrence Patihis, Department of Psychology, University of
Southern Mississippi, Owings-McQuagge Hall, 231, 118 College Drive, #5025, Hattiesburg, MS 39406. E-mail:
lpatihis@gmail.com

ously described evidence of false memory production in therapy during the 1980s and 1990s
(e.g., Goldstein & Farmer, 1993; Loftus & Ketcham, 1994; Ofshe & Watters, 1994; Pendergrast, 1996; Maran, 2010; Yapko, 1994), relatively little has been written about false
memories before this era. Rosen, Sageman, and
Loftus (2004) outlined one early case of possible false memory from the hypnotist Bernheim
in the 1880s, but did not document other evidence. Although others have investigated the
history of repressed memory (e.g., Esterson,
2001; Crews, 1995; Pope, Poliakoff, Parker,
Boynes, & Hudson, 2007) and early hypnotism
(e.g., Ellenberger, 1970; Kihlstrom, 2002; Laurence & Perry, 1988; Moll, 1889; Pintar &
Lynn, 2008), to our knowledge, few previous
researchers have carefully examined and compiled in a single source the early history of a
related but different topic: false memory in therapy and hypnosis.
In this article, we provide examples of memory distortion in psychotherapies, hypnosis, and
their precedents, based on a search of the pre1980 literature. We report findings that range
from the debatable (e.g., infantile memories that
may be false) to memories that are almost certainly false (e.g., memories of past lives).
Modern research on memory suggestibility
had precedents in works such as Ribot (1887),
Bernheim (1884), Binet (1900), and others.
Bartlett (1932) was one of the first to suggest

153

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PATIHIS AND YOUNES BURTON

and document that memory is reconstructive

and influenced by cultural expectations and
schemas that distort memory. Laboratory evidence of false memories accumulated further in
the 1970s, but mostly for details in a slideshow
or a video (e.g., Loftus & Palmer, 1974; Loftus,
Miller, & Burns, 1978). It was not until subsequent research, such as Laurence and Perrys
(1983) study of false memories in hypnosis, and
later Loftus and Pickrells (1995) demonstration
that it was possible to implant memories of
entire events, did some certainty regarding the
ability to implant complex memories emerge.
With the identification of memory distortion
techniques that followed, ranging from guided
imagery (Garry, Manning, Loftus, & Sherman,
1996) to associated word lists (Roediger & McDermott, 1995) and suggestions regarding nonexistent news footage (Crombag, Wagenaar, &
Van Koppen, 1996), it became clearer that false
memories could be induced with a variety of
methodologies. The fact that vulnerability to
memory distortion occurs in children (Sutherland & Hayne, 2001), young adults (Loftus,
Miller, & Burns, 1978), older adults (Wylie et
al., 2014), and even in individuals with superior
memory (Patihis et al., 2013), implies that susceptibility to memory distortion may be a fundamental aspect of the human mind that existed
long before the decades in which these studies
were done. In light of such research, it is reasonable to hypothesize that if we were to look
for evidence of false memories in therapy many
years before these discoveries, we would discover such evidence. If we succeed in doing so,
it could shed light on the precedent causes of the
memory wars, specifically providing insight
into early interventions that provided the theory
and techniques that subsequently influenced
therapies in the 1980s and 1990s.
In this article, we categorize evidence into
subheadings ranging from the weakest evidence
(early hypnosis) to the strongest (recovered
memories of impossible events). Within each
subheading, we organize the evidence chronologically with the earliest evidence first. First,
we briefly detail our method and delineate the
scope of the article.
Method, Scope, and Inclusion Criteria
To compile evidence for false memories, we
searched for historical accounts, especially first

person client accounts, involving autobiographical or episodic recall in therapy, hypnosis, or

precedent proto-therapies such as mesmerism.
We initially searched before the year 1980 only
and read original texts in both French (second
author whose first language is French) and English (both authors). We found that approximately 100 years ago, words or phrases such as
pseudomemory, retroactive hallucination,
and phantasy were commonly used to refer to
what we now call false memories. Moreover,
more than 100 years ago the term false memory, or more precisely fausse mmoire in
French, sometimes was used in a context related
to dja` vu, with closer inspection revealing a
meaning of the term that diverges somewhat
from current usage (e.g., in French see Sollier,
1892, p. 14; Arnaud, 1896, p. 516; in English
see Berrios & Hodges, 2000, p. 328). We also
incorporated feedback from knowledgeable
scholars in the area of memory and hypnosis,
and we examined historical reviews of early
hypnosis and therapy. Importantly, our search
revealed no prior scholarly source that provided
a detailed review or compilation of early evidence of false memory production in therapy.
We excluded a substantial amount of material
that did not meet our criteria. For example, we
only searched in the domains of psychological
therapy, hypnosis, and their precedents, which
for the purpose of this article, we define loosely
to include interventions such as mesmerismrelated practices and drug therapy. For this reason we excluded comments on the unreliability
of memory by early Greek philosophers or
Shakespeare, or possible hallucinations apart
from therapy (such as in medieval witch trails or
during religious miracles). We also excluded
possible yet not definitive confabulations, such
as Levinsons (1965) use of hypnosis to recall
spoken words while the patient experienced
general anesthesia (cf. Cheek, 1959) and
Grinker and Spiegels (1943) use of truth serum drugs in narcosynthesis to recover repressed memories of war-related events (see
also Kihlstrom, 1998; Horsley, 1936). What
these excluded examples have in common is the
recall of previously unaware of material,
which could be indicative of false memories,
yet unlike some of the events we document
later, could plausibly have occurred: only the
assumption that repressed memories are impossible would render the memories false.

FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980

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Figure 1 illustrates a timeline of milestones

related to the early history of false memories,
which we examine in greater detail in the sections that follow (1 through 7, below). In Section 1, we discuss the relative paucity of evidence in early mesmerism and hypnosis,
although there is no lack of evidence of perception distortion. In subsequent sections the evidence becomes progressively stronger.
Section 1: The Weak Evidence From the
Earliest Hypnotists
Some scholars, especially those familiar
with the early history of mesmerism and hypnotism, may be surprised to learn that we
found a lack of evidence of false memory
production during the late 1700s and early to
mid-1800s. Still, we did identify interesting
precedents of false memory formation, such
as perception distortion and the gradual emergence of issues concerning memory in mesmerism, including posttrance amnesia. Indeed, we regarded the question of whether we
would find evidence of pseudomemories in
early hypnosis and its precedents as open,
given that proto-therapies did not devote as
much attention to memory as later therapies.
In this article we stretch the domain of hypnosis to include precedents such as Johann
Gassners exorcism treatment of 1775 (a treat-

155

ment similar in some ways to mesmerism) in

which we find evidence of perception distortion.
For example, while treating patients Gassner
seemed to distort the beliefs and perceptions of
his patients by suggesting the devil was within
them and causing certain parts of their body to
shake (see Laurence & Perry, 1988, p. 6; Ellenberger, 1970, p. 54), but there seemed to be little
attempt to distort memories. Distortion of perceptions was reported specifically in one case in
which the patient, Emilie, was neither able to
hear or see while in the trance state, despite
having her eyes open (Laurence & Perry, 1988,
p. 21). According to Figuiers (1860, p. 136)
transcript of Emilies exorcism, the phrases
used were nihil modo audiat (nothing can be
heard) and apertis oculis nihil videat (nothing
is seen through open eyes). Perhaps Gassners
treatment is less a direct precedent of false
memory cases and formation and more of an
early foreshadowing of the satanic or multiple
personality cases of the 1980s.
In investigating Mesmer, we examined two
books in the original French text (Mesmer,
1779, 1781), an English translation of Mesmers (1980) work, as well as De Hornes
(1780) criticism of Mesmer. These texts indicate that although suggestion was used, it was
employed to suggest cure rather than induce
memory. Memory distortion could have happened accidently with Mesmer, but it was not

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

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

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PATIHIS AND YOUNES BURTON

well documented, nor was it his aim to retrieve

memories. It is possible that Mesmer induced
false perceptions using suggestion in a blind
patient named Maria Paradis, who allegedly reported seeing images and then subsequently reported becoming blind again (Pattie, 1979). The
distortion of perceptions seems to predate memory distortions in trance-inducing treatments
and perhaps was an important step toward the
development of false memory in later therapies.
The Marquis de Puysgur modified Mesmers techniques in ways that incorporated
more aspects of memory. For example, Puysgur was one of the first mesmerizers to consistently claim that his patients developed amnesia
of the trance state afterward (although Mesmer
may have already observed this; see Laurence &
Perry, 1988, p. 112). Nevertheless, in our reading of the original French texts (Puysgur, 1809,
1811, & 1812), as well as more contemporary
descriptions (Ellenberger, 1970; Pintar & Lynn,
2008; Laurence & Perry, 1988), we only could
find circumstantial evidence of memory distortion. In one case, Puysgur (1812) treated a boy,
Alexandre, who in the mesmerized state remembered that On ma t de la cervelle
(some of my brain was removed; Puysgur,
1812, p. 21). This could be a false memory,
given Alexandres fathers insistence that ce
ntait pas lopration du trpan (it was not a
trepanation surgery, p. 21). Nevertheless, it is
difficult to distinguish whether this was merely
a false belief or an actual false episodic memory
on the part of the boy.
In reading Scottish surgeon James Braids
(1943) work on hypnosis, we again found evidence of perception distortion (e.g., reduction of
pain sensations, p. 241; inducing sensation of
drunkenness, p. 45) but not false memory. Demarquay and Giraud-Teulon (1860) similarly
demonstrated perception distortion, especially
pain perception reduction (p. 19) and image
induction (p. 21). Another case of Demarquay
and Giraud-Teulon described a woman who
while hypnotized disclosed personal secrets, so
serious, so dangerous to herself, that it was our
responsibility to wake her (Philips, 1860, p.
160). It is unclear, though, whether she was
confabulating or not. It is possible this was a
distorted recovered memory, but it is also possible that the woman merely disclosed an event
that she had remembered all along.

As we have shown, there are clear indications

of perception and belief distortion in the earliest
mesmerizers and hypnotists, but little evidence
of false memories. Next, we discuss evidence
that is stronger than what we have presented so
far; that of therapy-recovered memories of
events before the age of three.
Section 2: Memories Before Age 3
Infantile amnesia of episodic memory in
adults is relatively well documented and appears to be caused by brain maturation and
language development during childhood (Howe
& Courage, 1993; Josselyn & Frankland, 2012;
Nadel & Zola-Morgan, 1984). If recollections
before age two or three (i.e., the onset of infantile amnesia) were not known to an adult client
before therapy, they are highly indicative of
memory construction and distortion.
In one of the earliest reports of such infantile
memory recovery, Sigmund Freud rather fleetingly implied that some of his patients recalled
reports of trauma as early as six months of age.
For example, Freud wrote, referring to one of
his adult patients, when the girl was six to
seven months old (!!), her mother was lying in
bed, bleeding nearly to death from an injury
inflicted by the father (Freud, 1897/1985; p.
289; Freuds original exclamation points
shown). Freud made several other references to
early memories. For example, he also reported
that an adult patient remembered the first half
of her second year, she saw herself sucking at
the nurses breast (Freud, 1901/1953, p. 52).
Although further searches of Freuds work
failed to uncover evidence of the types of impossible or highly implausible memories that
we document in later sections, there are further
clues that he may have created false memories.
For example, Laurence, Day, Gaston, and Lynn
(1998) identified the following excerpts where
Freud demonstrates how he was persistently
insistent that recovered memories were real,
even when his patient told him the incidents had
not actually occurred:
There are cases, too, in which the patient tries to
disown [the memory] even after its return. Something
has occurred to me now, but you obviously put it into
my head. . . . In all such cases, I remain unshakably
firm. I . . . explain to the patient that [these distinctions]
are only forms of his resistance and pretexts raised by
it against reproducing this particular memory. (Freud,
18931895/1953, pp. 279 280)

FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980

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Even when the analyst fails to uncover a false

episodic memory, Freud wrote that at the very
least the analyst should encourage a strong belief in the patient that some major event has
been repressed:
Quite often we do not succeed in bringing the patient to
recollect what has been repressed. Instead of that, if the
analysis is carried out correctly, we produce in him an
assured conviction of the truth of the construction
which achieves the same therapeutic result as a recaptured memory. (Freud, 1937/1953, pp. 265266)

These excerpts are somewhat ambiguous, and

therefore it is difficult to be sure of the extent to
which Freud implanted false memories.
Although Freud appears to be one of the first
to uncover infantile memories, many others
continued the practice long after Freud developed doubts about the utility of such practice
(starting in Freud, 1905). For example, in the
1920s the American psychiatrist Anita Muhl
used a technique involving gazing into crystals
and involuntary writing to help her patients to
recover early memories. For example, Muhl
(1924) regressed a 15-year-old female, Marjory,
who recalled: [Melda] was very sorry for what
she did and she cried to take care of me and that
was when I was two and a half years old
(Muhl, 1924; p. 269). The same patient also
recalled the following from 15 months of age:
I see a child playing on the ground. I cant see what she
is doing. Now she is getting up and turning out the
water. Now she is going into a door. She is inside the
house now. The picture is fading. (Muhl, 1924, p. 270)

Notice the present tense usage of the patient

indicating that the memory was coming back to
her, a pattern repeated in several examples in
the current article. The patient also recalled that
in this same incident she was just beginning to
walk (p. 270). It is clear that Muhl believed
that she was regressing patients to experience
actual memories. For example, she wrote that
her therapy was a method of recalling forgotten incidents (Muhl, 1924; p. 264). As such,
Muhls therapy might be considered an early
example of memory recovery therapy, although
there is some uncertainty regarding whether
these events are actually false.
Here we have provided a few cases of infantile memory recovery in therapy before 1980. A
few other writers have also reported memory
recovery of events in the first 2 years (e.g., Grof,
1976, p. 65; Hubbard, 1950, p. 169; Janov,

157

1970; p. 110). Nevertheless, there is even stronger evidence of false memories to document
from these and other authors in the next section.
Section 3: Memories of Birth or Womb
Because the brain is still immature around
birth, exhumed episodic memories of perinatal
or prenatal life could well be good evidence of
false remembrances. Austrian psychoanalyst
Otto Rank (1924, 1929), originally Freuds
mentee, proposed the idea that birth itself was a
major trauma, reflecting an important psychological change. According to Rank, people unconsciously aspire to return to their mothers
womb in an ultimate attempt to overcome their
birth trauma. Despite this theoretical proposal
and his practicing of psychoanalysis, we could
not find a case study of one of Ranks patients
reporting an episodic memory of birth. It is
uncertain, then, that Rank induced false memories of birth. Nevertheless, he may have influenced others who later reported birth memories
more explicitly.
The earliest evidence of memories of birth we
found came from L. Ron Hubbards (1950) Dianetics book. For example, the author describes
a patient who under drugs, went back to his
birth. During the reliving, he suffered the pain
and fought the doctor who had tried to put drops
in his eyes (Hubbard, 1950; p. 86). Even more
remarkable are the authors descriptions of prenatal memories and the idea that recording of
memory engrams begins very early:
And suddenly it was discovered that recording begins
in the cells of the zygotewhich is to say, with conception. That the body recalls conception, which is a
high level survival activity, has little to do with engrams. Most patients to date sooner or later startle
themselves by finding themselves swimming up a
channel or waiting to be connected with. The recording
is there. (Hubbard, 1950, p. 88)

As is true of other types of false memories,

hypnosis seems to be implicated in a number of
reports of birth and womb memories. For example, British psychiatrist Denys Kelsey used
hypnotic age regression to recover a memory in
patient Miss F of her life in her mothers
womb. Miss F, during hypnosis, reported that I
am very tiny . . . This is the womb (Kelsey,
1953; p. 217). As before, notice the use of the
present tense indicating a memory being experienced almost like a reliving episode. Miss F

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PATIHIS AND YOUNES BURTON

went on to report that there is something beating in me and through me- my mothers heart. I
cant see and it feels as if Ive got no mouth (p.
218). Another patient (Mrs. M) regressed back
to her 7th month in her mothers womb. She
describes a burning sensation that she attributes
to an attempted abortion from her mother.
Kelsey writes she was quite certain that the
burning was due to something which her mother
was doing to try to get rid of her (p. 219).
Later, she reaches a birth memory where she:
Felt someone get hold of her legs and pull them out.
Then something hard and painful got hold of her head
and began to twist it. Then she was lying on something
white and felt she was choking from something round
her neck. She was aware of a man and a woman, both
dressed in white, and someone shrieking, I dont want
her! I dont want her! (Kelsey, 1953; p. 219)

Kelsey also described recovery of experiences as far back as conception. Kelsey described that a patient Mr. A had eventually
reached his conception, in which he saw himself
as the ovum being raped, rather than wooed, by
the overanxious sperm of his overanxious father (Kelsey, 1953, p. 221). The fact that
Kelsey (1953) claims that he is open to the
possibility that these memories might be phantasies (p. 216) does not diminish the evidence
that false memory production occurred in therapy long before the 1980s and 1990s.
David Cheek (1974, 1975; see also Cheek &
LeCron, 1968) also appears to have induced
birth memories in patients. Cheeks method involved hypnosis as well as techniques derived
from ideomotor theorythe idea that unconscious body movements can signal state-bound
memories. Cheek (1974) suggested that the observation of automatic bodily movements that
resembled those of a baby struggling to be born
were evidence that age regression may be uncovering valid memories.
In the 1960s and 1970s, other therapists, often using different techniques, also reported
memories of birth and intrauterine experience.
For example, American clinical psychologist
Arthur Janov, instead of using hypnosis, used a
technique of ostensibly blocking clients neurotic defenses that eventually led back to the
reliving of their early traumatic events. Janov
reported a case study of a patient Gary who
was reported to have said:

I saw myself being conceived in her belly. Next scene

she is in the hospital having the baby. Only this . . .
baby is ME. I am born strangled by the umbilical cord.
Mommy is yelling, Die . . . I dont want it. Let it die.
(Janov, 1970, p. 186)

Later, Gary adds finally I was born! I was

breathing. I also remembered I was being held
around the ankles upside down (p. 197).
Czech psychiatrist Stanislav Grof used completely different methods, albeit with similar
results, in his lysergic acid diethylamide (LSD)
therapy. This therapy involved a combination of
ingestion of the hallucinogen LSD and psychotherapy methods. For example, a patient (a psychiatrist himself) remembered being in the
womb:
I was greatly reduced in size, and my head was considerably bigger than the rest of my body and extremities. I was suspended in a liquid milieu and some
harmful chemicals were being channeled into my body
though the umbilical area. Using some unknown receptors, I was detecting these influences as noxious and
hostile to my organism. (Grof, 1976, pp. 111112)

This same patient visualized his conception

and uterine development: to my utter astonishment, I relived my own conception and various
stages of my embryological development
(Grof, 1976; p. 113). Even more surprising, the
patient went on to say while I was experiencing all the complexities of the embryogenesis,
with details that surpassed the best medical
handbooks, I was flashing back to an even more
remote past, visualizing some phylogenetic vestiges from the life of my animal ancestors
(Grof, 1976; p. 113). Grof goes on to describe
other case studies of patients who reexperienced
intrauterine events while under the influence of
LSD (Grof, 1976; p. 136, 161, 236). It is unclear
whether it was the hallucinogenic effects of the
drug that aided the visualization of these memory constructions, the therapeutic techniques, or
a combination of these potential influences.
Many of the examples in this section provide
strong indications of false memory production
because they involve episodic memory recall
during the infantile amnesia period. They also
reflect the dubious proposition of an infant understanding and encoding language before the
perinate had mastered language perception.
This section and the one that follows on implausible satanic abuse provide similarly strong evidence of false memory production in therapy.

FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980

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Section 4: Satanic Ritual Abuse

Although there are historical precedents of
alleged satanic ritual abuse activity, they either
did not meet our criteria of being induced by
therapy or hypnosis, or they did not involve
episodic memory recovery (e.g., medieval witch
trials, Nathan & Snedeker, 1995, p. 31; Goode
& Ben-Yahuda, 1994, p. 57). The first case that
did meet our criteria was the famous case presented in the book Michelle Remembers (Pazder
& Smith, 1980). In 1973 an adult patient, Michelle, started therapy with Canadian psychiatrist Laurence Pazder, and through hypnosis
subsequently recovered severe satanic ritual
abuse memories (beginning in 1976). Michelle
recovered memories of a 2-year period (when
she was ages 57) in which she remembered
being in a satanic cult with her mother. She had
no memory of this before therapy. Her revelations included a series of sacrifices and cannibalistic rituals:
Hes pushing on my tummy. It feels like my insides are
going to squish out. The nurse is doing something
down below. I want to see if my insides are coming out
. . . I looked down, and there was this little thing lying
there . . . it was a baby! A baby!! No! He stabbed the
baby with it! Not with that, no! You cant stab the baby
anymore, its just a mess. They rubbed it all over me
. . . the baby. On my face, my chest. (Pazder & Smith,
1980, pp. 125126)

Michelle also recalls being kept captive and

naked in a cage with snakes [that] werent
poisonous. (Pazder & Smith, 1980; p. 141).
In another session, she recalls being taken
into a room where several bodies were seen
on stretchers. They seem alive, she says, and
when a doctor came in the room he picked
metal knives and started dismembering the
bodies; He cut off its feet! . . . I can hear him
cutting its legs. I can hear him cutting the
bones up (p. 177).
As unlikely as they are, the events so far are
at least physically possible. Nevertheless, Michelle goes on to describe memories of supernatural beings. She describes how Satan was
summoned and eventually removed Smiths
scars, thus erasing any evidence of the alleged
abuse, and also erased her memories of the
events until the time was right (Pazder &
Smith, 1980; p. 242). Michelle also describes a
memory of when Satan took her on a visit to

159

Hell and introduced his armies of the living

dead:
Theres people with no arms that are bleeding . . . Theres
people with no eyes, and theyre bleeding from their eyes.
Theres people thats got no noses! And theres people
that got ears cut off. (p. 244)

She also remembered a sacrifice of a girl by

Satan himself (p. 249).
Given the supernatural aspects of some of
these memories, they are likely indicative of
false memory formation during the hypnotic
sessions. Even without the supernatural aspects,
several investigations found no corroboration of
the events portrayed in the book (e.g., see Allen
& Midwinter, 1990; Grescoe, 1980; Nathan &
Snedeker, 1995; Spanos, 1996). One possible
alternative explanation is that the authors deliberately fabricated the stories, without actually
having visual memories, perhaps to help sell
books. Whatever the evidentiary value for
memory distortion, it is entirely possible that
this book influenced other satanic ritual abuse
scares that followed in the 1980s and 1990s,
such as the McMartin preschool and Faith Chapel Church cases, and by extension contributed
to the memory wars of the 1990s. A number of
authors have noted that there is very little substantial evidence for most, if not all, cases of
satanic ritual abuse. For example, Lanning
(1989), in a report for the FBI, concluded that
there was a general lack of physical evidence
for allegations of ritualistic Satanic cult activity
(see also Nathan & Snedeker, 1995).
Section 5: Memories of Past Lives
The most convincing evidence for false
memories in therapy pertains to memories that
are widely considered to be scientifically impossible. Although some early civilizations believed in reincarnation and some contemporary
religious communities continue to adopt such
beliefs, until recently, it was a uncommon for
people to claim that they could remember past
lives. Some forms of Buddhism hold that only
individuals under the age of six can remember
past-lives. Hinduism also involves a belief in
reincarnation. Following the migration of a
number of Indian gurus to Europe at the end of
the 19th century, interest in past lives thrived
and then morphed into the idea that adults can
remember past lives.

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Perhaps influenced by precedents in Hinduism and Buddhism, one of the first cases to
involve memories of past lives appears to be
that observed by Thodore Flournoy, a professor of psychology at the University of Geneva.
Flournoy (1899/2007) observed a purported
psychic medium recall/experience reincarnations as a Hindu, as Marie Antoinette, and as a
being on the planet Mars (to be discussed further in the next section). Flourneys report of
this trance-like state, although not exactly utilizing hypnosis or therapy, could have influenced subsequent early examples of past life
memories during hypnosis in the early 1900s.
For example, Albert de Rochas, a military
man who practiced hypnosis, described a person
he worked with in 1904. De Rochas (1911) used
hypnosis to regress a patient, Josephine, back to
previous lives. Josephine then remembered life
as a man born in 1812 (p. 38), then a little girl
who died at a very young age, and later as a man
who had killed and robbed (p. 40). Most interestingly, she eventually regressed down the
evolution chain and remembered life as an ape
(p. 41). De Rochas did not stop his demonstration there; he progressed Josephine into the
future. He called this technique precognition.
He asked Josephine to describe her life when
she will be 40 years old. She seemed to form a
memory of the future in which she has a baby
with a man named Eugene F, but the baby died,
and then Eugene married another woman. When
de Rochas attempted to progress the patient
further in time, Josephine fell on her back, to the
ground. In this future memory she was dead,
and she witnessed her own funeral (p. 43).
Perhaps even more incredible, if that is possible, are the memories of another patient of de
Rochas, Madame Roger. During a hypnotic session in 1905 she recalled being in the state of a
spirit: I am traveling [in the space], I was told
[I lived on earth] but I left my body (de
Rochas, 1911; p. 95). When Mme Roger is
asked to take the form of a human body again
she claimed her name was Madeleine Beaulieu
and it is 1724. Later, she recalled another past
life in which she was now 48 and her name is
Philibert. She explained that Louis XIV
(1638 1715) is ruling the country (p. 98).
We also found more recent accounts of episodic memories of past lives, again in hypnosis.
Morey Bernstein was an amateur hypnotist who
treated a patient called Virginia. Bernstein

(1952) hypnotized Virginia and gradually regressed her back to her childhood, then before
birth and eventually he regressed her one step
further, into a previous life (Bernstein, 1952).
Virginia remembered being Bridey Murphy
(1798 1864) a housewife living in Cork, Ireland. Her first memory of her life as Bridey
started when she was 8 years old. She recounted
her childhood with her dad who was a barrister.
She remembered her marriage with a man
named Brian when she was 17. She described
Brideys own death as well, when she fell from
a horse. She was even able to recall her funeral:
[I was] 66 when I died. I watched them ditch
my body. (Bernstein, 1952; p. 161). She recalled the visual image of the date on her tombstone: [It] was on the tombstone . . . I see one
eight six four. Bridget . . . Kathleen . . . MacCarthy. One . . . seven . . . nine . . . eight . . . a
line and then . . . one-eight-six and four. (Bernstein, 1952; p. 161). Bernsteinss book contains
many other rich and detailed purported autobiographical recollections from the past life. The
patient, Virginia, and Bernstein seemed convinced of the truthfulness of Virginias past life
memories. The Bridey Murphy case attracted
criticism within a few years of publication, including Klines (1956) compilation of skeptical
essays, which included psychiatrist Harold
Rosen describing the case as pseudoscience
(p. xv). A Life magazine article also cast doubt
on the case, noting failed attempts to find evidence of Bridey Murphys birth or death records
(Brean, 1956).
The popularity of the Bridey Murphy story
and Bernsteins (1952) book, along with earlier
accounts, may have led to subsequent past life
memory recovery. For example, hypnotherapist
Dr. Arnall Bloxham regressed a patient, Jane
(age 30), into six different past lives (Iverson,
1976). The earliest recalled life was as Livonia, wife of Titus in Roman Britain during the
3rd century in AD 286. The patient went on to
recall lives in 1189, 1450, the early 16th century, 1702, and the early 20th century. In 1189
she was Rebecca, a wife of a wealthy Jewish
moneylender: it is the Christian year of 1189
(Iverson, 1976; p. 33), and good King Henry
has died and King Richard is away, in the
crusades (p. 40).
Also in the 1970s, American clinical psychologist Edith Fiore (1978) described eight cases of
patients who recovered memories of previous

FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980

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lives under hypnotic age regression. For example, the first case depicted in the book, Becky
(age 22), recovered memories of her past life as
girl several centuries ago.
Dr Fiore:

What is your name?

Becky:

Elaine?

Dr Fiore:

How old are you?

Becky:

Fifteen.

Dr Fiore:

On the count of three the date

will occur to you . . . What come
to your mind?

Becky:

1664. (Fiore, 1978; p. 30)

Becky, still experiencing hypnosis, described Elaines death when she was raped
and stabbed by three men: [I feel] cold . . . I
feel like Im watching . . . I think Im dead. [I
see] the three men run away. (pp. 42 43).
Even more bizarre, she identified one of rapists as a past incarnation of Beckys own
father. The therapist, Fiore, asked the father
to join his daughter during a therapy session.
Beckys father seemed to accept the idea that
in a previous incarnation he had murdered a
previous incarnation of his daughter and
could not help but apologize for what he had
done to his daughter.
Around the same period as Fiore, American
past life therapist Dr. Morris Netherton (1978)
described similar case studies. One patient,
Carl, recalled a past life in primitive times, in
a village in South America or Africa. In this
past life, he slept with the wife of one of his
rivals, and when the husband came back to the
hut: he hurls that spear and hes got me, right
there in the gut. Still conscious after he was hit
by the spear, his assailant continued the attack:
Now hes reaching down and hes cutting it
off. My penis . . . I cant feel it (Netherton,
1978; p. 58).
Unfortunately, Netherton also treated an
11-year-old child, Chuck, who recovered
memories of his in utero life as well as horrific memories of a previous life: Im a very
little baby. Im not really a baby yet. Im
inside still. Im three months along. (Netherton, 1978; p. 108). Chuck remembered,
while still in his mothers womb, hearing
when the pregnancy was revealed. He heard
the grandmother say that there is nothing to

161

be calm about, and he recounted how that had

affected him. Later, he regressed back even
further and reexperienced one of his past reincarnations: Im in a cell. Like a jail cell.
Im a prisoner (p. 110). Chuck reported it
was the 1940s, and that he was on death row
in prison for murdering his infant. He remembered: theyre strapping me to a chair. Its
the electric chair. A sudden burst like white
lights, but in my head. My body is bouncing
in the chair . . . And it stops. As if this
memory was not enough for the child patient,
he then remembered hearing: Hes an active
one hes not dead yet. Then, the second
shock: Theres another burst in my head.
They turned it on again. Im dead (p. 110).
Past life memories have been recovered not
only with hypnosis but also with LSD therapy. For example, Grof (1980) describes a
patient, Tanya, a 34-year-old teacher at the
time, remembering a previous incarnation as a
young girl from New England who was accused of witchcraft (the year is not known,
but it may be the witch trials of the late
1600s). She remembered how the villagers
had taken her to the birch-grove and drowned
her. She recognized among her attackers, two
men from Tanyas present life: past incarnations of her father and husband (p. 288). The
latter pattern of incorporating present day
faces into impossible memories of past lives
demonstrates how people can confabulate and
reconstruct memories from both real and
imagined sources.
Evidence of episodic recall of past lives is
strong evidence of memory distortion because
there is little or no credible evidence for actual occurrences of past lives. Although Stevenson (1994), in an otherwise skeptical article, claimed that there may be very rare cases
that offer some evidence of past lives, methodologies of studies supportive of past lives
have met with considerable criticism (see
Mills & Lynn, 2000). Similarly strong evidence of false memories is associated with
another type of impossible memory: abduction by space aliens.
Section 6: Memories of Alien Abduction
Reports of space alien abduction are a fascinating demonstration of the distorting power of
hypnosis, imagination, and suggestion on mem-

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162

PATIHIS AND YOUNES BURTON

ory. A number of early precedents of reports of

alien encounters not involving therapy or hypnosis do not match our criteria for inclusion
(e.g., Swedenborg, 1758; Vilas-Boas in 1957,
see Denzler, 2003). In addition, Flournoy
(1899/2007), as briefly mentioned in the previous section, did report a woman who appeared
to be in a trance-like state remembering a reincarnation as an entity on the planet Mars. This
experience of inhabiting a Martian was accompanied by talk that the woman construed as a
Martian language. Flournoy himself suspected
the Mars experience was the product of imagination and expressed skepticism regarding this
phenomenon, albeit not complete skepticism
(see also Hyslop, 1900). This report did not
involve a memory of a physical encounter with
aliens, although it was an interesting precedent.
American author John Fuller described one
of the earliest reports of a physical (as opposed
to psychical) alien abduction. In Fullers (1966)
story a couple remembered, after months of
hypnotherapy, their trip into a spaceship in
which they were medically examined by strange
creatures from outer space. In 1961 Betty and
Barney Hill were driving home from vacation
when they noticed a strange light in the sky.
According to Barney, the light was moving in a
strange and unconventional way. When they
arrived home, the couple was surprised to see
they were two hours late on their schedule; time
was missing, which they could not explain.
Betty underwent seven months of therapy before she recovered episodic memories of the
aliens facial features: eyes continued around
the side of the heads and had two slits that
represented the nostrils (Fuller, 1966, p. 305).
She remembered being on an examination table
when they put a needle into [her] navel as part
of a pregnancy test, and skin samples were also
collected (p. 195). Fullers work perhaps was a
precedent that inspired abduction memories after 1980; for example, those reported by Harvard psychiatrist John Mack and others (Mack
& Mack, 1994; see also Clancy, 2005).
Impossible memories are one way to confirm
that the episodic recall was inaccurate, but another way is when the therapist or experimenter
deliberately manipulates memory and knows
that the implanted event did not happen. In the
next section, we discuss the relatively strong
evidence in which therapists acknowledged
memory distortion.

Section 7: Therapist Acknowledged False

Memories
Perhaps the most surprising evidence we obtained were cases in which the therapists themselves admitted to creating false memories in
their clients. We say surprising because we
found a number of cases that seem to have been
forgotten by many and predate the purportedly
recent idea that distorting memory could facilitate treatment (e.g., Nader, Hardt, & Lanius,
2013). The therapists describe how they intentionally modified their patients memory, sometimes claiming that it was beneficial and for
curative purposes, and at other times demonstrating the dangers of suggestion.
The earliest account we found of a false
memory that a therapist acknowledged dates to
the 1880s. Hippolyte Bernheim was a French
physician who described cases from the early
1880s that involved the concept of retroactive
hallucinations (Bernheim, 1884, 1889). As we
decoded this old terminology, it became clear
he was talking about remembering false memories (hallucinations) about the past, in the
present (i.e., retroactive). During hypnosis,
Bernheim (original French: 1884; English translation: 1889) suggested to his patient Marie that
she had witnessed an old bachelor rape a young
girl. Marie is told she could see the little girl
struggle and bleed. At the end of the hypnotic
session, Bernheim added that it is not a dream;
it is not a vision I have given you during your
hypnotic sleep; it is the truth itself; and if inquiry is made into this crime later on, you will
tell the truth. (Bernheim, 1889, p. 165). A
friend of Bernheims questioned Marie three
days later. She gave him a perfect recollection
of the alleged event; the name of the rapist and
his victim, as well as the date, time, and place of
the crime. Bernheim, in an attempt to test Maries confidence in her testimony, asked her if it
was not perhaps a vision like those [he] was in
the habit of giving her during her sleep (Bernheim, 1889, p. 165; original French in Bernheim, 1884, p. 12), but Marie remained adamant
of the veracity of the story. She even agreed to
testify at a trial, under oath. Bernheim wrote
that he later used hypnosis to successfully remove the implanted memories. Interestingly,
like modern false memory researchers, he urged
caution in the use of suggestion by magistrates

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FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980

and warned of false evidence given by children

in court (Bernheim, 1889, pp. 176 177).
In contrast to implantation of false traumatic
memories as described by Bernheim, French
psychotherapist Pierre Janet (1894) described a
case of erasing a true memory. Janet described
a client, Justine, who had been obsessed with an
intense fear of contracting cholera. They traced
the phobia back to an incident 20 years earlier
when she saw two corpses of people who had
died from the disease. Janet wrote:
I transformed the appearance of the cadavers, and
above all I spent several sessions dressing them. The
hallucination of a garment, and then another, was fairly
successful, and finally the main body seemed saddled
with the costume of a Chinese general that Justine had
seen at the exhibition. The success was mostly full
when I managed to get the Chinese general to stand up
and walk, it was not terrifying anymore but rather
comical. (Janet, 1894, p. 128)

Although not as clear as the Bernheim and

Janet examples, we also found circumstantial
evidence of distortion during the hypnosis done
by French neurologist Jean-Martin Charcot.
Charcot (1887) describes how a patient seemed
to reconstruct a memory of a traumatic accident:
of the accident itself he does not remember
much, despite what he says, and it is likely that
everything he says, he dreamed it or unconsciously constructed it, exaggerating everything
he heard or was told (p. 456; our translation).
Similarly, one of Charcots patients suffered
amnesia after hurting his head, and Charcot
writes he recovered memory of the incident
after he heard people around him talking about
it (pp. 442 443; our translation). Like Bernheim and Janet, Charcot acknowledged memory
construction in patients, but it is less clear what
the events he referred to are and to what degree
hypnosis induced the distortion.
There are interesting parallels between the
more recent memory wars of the 1990s and the
time period of Bernheim, Janet, and Charcot,
such as the legal implications of memory distortions. Indeed Laurence and Perry (1988) discussed some of these legal implications even
before the proliferation of legal cases of the
1990s related to the recovery of repressed memories. For example, Ligeois (1884), a fellow
member of the Nancy school of hypnosis with
Charcot, wrote about the legal implication of
hypnotic suggestion. Similarly, in what appears
to be a parallel to the skepticism-inspired re-

163

search of the 1990s, Hull (1930) and Young

(1927, 1931) had doubts regarding some of the
elaborate claims of hypnosis and described controlled research that revealed a more sober assessment of the power of hypnosis. In particular, Hull and Young doubted the ability of
hypnosis to enhance memory, although they
seldom mentioned or researched false memories
directly.
Even more bizarre than the implantation of
past events are constructed memories of the
future. Psychiatrists Rubenstein and Newman
(1954) published a report in Science describing how they had hypnotically progressed a
group of five subjects to a future time 10
years in the future. They described, in detail,
their activities at the future given date. They
noted that the participants fantasied a future
as actually here and now. They suggested
that many descriptions of hypnotic regression
also consist of confabulations and simulated
behavior (Rubenstein & Newman, 1954; p.
473). They were skeptical of these techniques
and challenged the validity of hypnotic regression. Nevertheless, perhaps they were unaware of Bernheim (1884) and Janets (1894)
work discussed above, because Rubenstein
and Newman (1954) go on to make the rather
unfortunate remark that their skepticism
about hypnotic regression probably does not
apply to the reenactment of traumatic past
experiences (p. 473).
As described, there are numerous examples
before 1980 when therapists purposely induced
false memories. They did so to either demonstrate the malleability of memory or to demonstrate the treatment potential for such techniques. If we take these authors at their word,
and in light of recent false memory research we
have good reason to do so, this presents strong
evidence that false memories occurred in psychotherapy before the more recent controversy.
Discussion
The standard narrative of false memories in
psychotherapy involves a story of how the phenomenon arose in the 1980s and caused a controversy in the 1990s. Here, we have documented
many earlier examples of autobiographical memories implanted in therapy. The evidence we presented ranged from 1884 to 1980 and ranged in
strength from infantile memories to physically

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164

PATIHIS AND YOUNES BURTON

impossible memories. We showed that some therapists openly acknowledged the implanting of entire autobiographical events, whereas others implanted memories without knowing that they were
most likely false.
The strongest evidence for false memories
earlier in history, paradoxically, may come
from sources that before the advent of recent
false memory research we might have deemed
unreliable. That is, before 1980, some skeptics
may have thought that reports of episodic memories of the womb, past lives, alien abduction,
and bizarre satanic rituals, constituted completely unreliable evidence because the authors
were either lying or deluded. However, in light
of the last three decades of false memory research, especially the creation of autobiographical false memories using techniques similar to
those used in therapy (hypnosis: e.g., Laurence
& Perry, 1983; guided imagery: e.g., Garry et
al., 1996; suggestion: e.g., Loftus & Pickrell,
1995), we argue that many or most of the cases
discussed in this article are not evidence of
deliberate deception, but evidence of memory
distortion.
Recent research has shown that it is possible
to instantiate false memories in the laboratory.
Some of these studies use or model some of the
techniques and target the types of memories
described earlier in this article. For example,
Spanos, Burgess, Burgess, Samuels, and Blois
(1999) demonstrated that suggestion could lead
to false memories of infancy. Specifically, following suggestion, some participants reported
remembering a colored mobile in the first few
days after birth, and some reported body memories in the form of itching around the umbilicus. Such memory distortion was found following both hypnosis and nonhypnotic
suggestion. Likewise, Malinoski and Lynn
(1999) used imagination and suggestive techniques in a series of interviews that resulted in
ever-earlier reports of their first memories. Before the interviews, the mean age of first memories was 3.7 years, and afterward it had decreased to 1.6 years, with 33% of participants
reporting memories before the first year of life.
In other research relevant to our article, Laurence and Perry (1983) demonstrated that hypnotic suggestion during an age regression exercise could create false remembrances of
awakening to a loud noise. Indeed, in a review
of hypnotic age regression research, Nash

(1987) concluded that the technique does not

reliably recover real memories of childhood,
and that behavior of patients when age regressed is not accurately childlike. In research
relevant to past life memories, Spanos, Menary,
Gabora, DuBreuil, and Dewhirst (1991) showed
that past life memories can be created in the
laboratory with hypnotic procedures and that
these memories can be manipulated by altering
participants expectations regarding past life experiences. Implanting false memories of alien
abduction might be considered unethical in a
laboratory study, but Clancy, McNally,
Schacter, Lenzenweger, and Pitman (2002)
were able to show that participants who claimed
to have been abducted by aliens were more
susceptible to false memories of words that
were not actually presented in the lists of semantically related words they had seen.
False memory research over the last few decades has also shown that diverse samples of
people, and indeed animals, are vulnerable to
memory distortion. More specifically, the pliability of memory has been demonstrated in
individuals with very good cognitive ability,
such as young adults at top universities (e.g.,
Goff & Roediger, 1998) as well as in people
with superior autobiographical memory (Patihis
et al., 2013). Importantly, individual differences
measures, including personality types, do not
predict memory distortions very strongly (e.g.,
Zhu et al., 2010), which further reinforces the
idea that false memory susceptibility is roughly
evenly distributed throughout the population,
implying that it may originate from a fundamental aspect of cognition. This speculation is reinforced by research in mice suggestive of false
memories (e.g., Ramirez et al., 2013) and also
by memory reconsolidation research (e.g., Nader, Schafe, & Le Doux, 2000). In addition, a
number of legal cases have also suggested that
that some memories, even though genuinely and
confidently believed in, are nonetheless false
(e.g., see Eberle & Eberle, 1993; Johnston,
1988; Loftus & Ketcham, 1994; Montoya,
1995). Recently acquired empirical findings, accumulated over the past 20 years or so, therefore shine new light on false memory production before 1980.
With respect to the writings before 1980, it is
striking how theory about memory seemed to
blind practitioners and clients to the obvious
fact that they were creating false memories. It

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FALSE MEMORIES IN THERAPY AND HYPNOSIS BEFORE 1980

was as if they were part of a failing scientific

paradigm (cf. Kuhn, 1962) in which they had to
work ever harder to fit the data within their
theoretical framework. For example, the theory
of cellular memory probably contributed to
false memories of being in the womb (e.g.,
Hubbard, 1950), the theory of active repression
of trauma appeared to be a major culprit in
creating false memories of severe trauma (e.g.,
Freud, 1896/1953), and the theory that consciousness could transcend death no doubt contributed to recall of past lives (e.g., Netherton,
1978; cf. Spanos et al., 1991). In many such
theories the lack of falsifiability of core constructs is an issue, and this is perhaps why
advocates of such theories have not conducted
research that actively seeks disconfirming evidence (see Popper, 1957).
The evidence we have presented has some
noteworthy limitations. Findings based on anecdotes and case studies are not as scientifically
valid or definitive as repeatable findings derived
from controlled laboratory experiments. Nevertheless, our reliance on case studies to some
extent was unavoidable. That is, we sought evidence of autobiographical memory distortion
in psychotherapies and separately considered
research that yielded ample and convincing evidence of memory distortion. Moreover, we
may have failed to identify one or more potentially relevant sources published during the past
200 years. We also were unable to include therapy-induced false memories of plausible events
that could have occurred but did not actually
occur. Accordingly, our account probably underestimates the true nature and prevalence of
false memories in the early history of therapy
and hypnosis. In addition, even with regard to
our strongest evidence, the possibility exists
that the original author or client engaged in
conscious or nonconscious deception. Nevertheless, given the theories about memory (e.g.,
repression, cellular memory) held by practitioners and clients, as well as recent evidence that
therapy-like techniques can induce false memories, we argue that many of our examples
genuinely involved memory distortion.
Conclusion
We conclude that memory recovery was generally not an aim of hypnosis until the 1880s,
and the years that followed seem to have

165

planted the seeds for the controversies regarding

memory that erupted in the 1980s and 1990s.
Given our findings, we contend that the widely
held, yet limited historical narrative of false
memories in psychotherapy can be expanded.
Rather than a story of how false memories
emerged in the 1980s and 1990s, we can now
better appreciate the historical antecedents of
false memories and iatrogenic methods in hypnosis and psychotherapy. In demonstrating relatively clear evidence of false memories in therapies before the 1980s, it is now a tenuous
argument to maintain that false memory production in therapy is a politically motivated
myth propounded by a number of individuals on
one side of the 1990s memory wars. The historical roots of debates regarding false memory
formation might be useful to disseminate to the
general public, who might encounter highly
critical information about false memory research on the Internet. The long history of memory distortion in therapy might also be useful to
share with clinical psychologists in training
who may benefit from knowing what has gone
askew in the past to prevent the repetition of
such mistakes. Historically, clinical psychology
PhDs have had license to devise their own therapies or modify existing ones, and this is still
true today. For this reason, new clinicians may
continue to engage in potentially harmful and
suggestive therapies that distort memory; our
hope is that this article will help to prevent or
mitigate that practice.
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Received September 20, 2014
Revision received January 12, 2015
Accepted January 14, 2015