“Memories recovered in therapy are not trustworthy"
“It is impossible to ascertain whether memories recovered in therapy accurately portray past events.” - Alexander Bodkin, in the FMSF Newsletter. 
“Families whose members had memories ‘recovered in therapy -- memories that had no basis in reality’ There are still people languishing in prison, convicted on the basis of memories that were created by invasive psychotherapeutic intervention.” - David Canter, in the FMSF Newsletter. 
Therapy does not necessarily increase the inaccuracy or falsehood of memories, whether they are continuous or recovered. In a study by Dalenberg, where both victims and perpetrators were interviewed, memories recovered in therapy were found to be just as accurate as those that were continuous.
Abstract: “Seventeen patients who had recovered memories of abuse in therapy participated in a search for evidence confirming or refuting these memories. Memories of abuse were found to be equally accurate whether recovered or continuously remembered. Predictors of number of memory units for which evidence was uncovered included several measures of memory and perceptual accuracy. Recovered memories that were later supported arose in psychotherapy more typically during periods of positive rather than negative feelings toward the therapist, and they were more likely to be held with confidence by the abuse victim.” 
A study by Leavitt tested whether or not recovered memories of abuse were created by specific therapeutic practices. Practices used by therapists on patients who happened to recover memories during treatment were tested on a separate population. After two years of treatment, even the most suggestible participants did not recover memories. As such, Leavitt concluded that “claims involving simple cause and effect relationships between treatment and memory recovery are not viable,” and that they are “not relevant for understanding the emergence of memories of childhood sexual trauma.” 
Many of the cases in the corroborated cases archive involved memories recovered in therapy. The two examples of recovered memories described in the previous argument concerning accuracy, “Claudia” and R v. Thomas Bowman, were both recovered in therapeutic settings. These are two other examples of accurate memories recovered in therapy:
State v. Wilson: Twelve jurors found Thomas Dean Wilson guilty of incest and third-degree sexual abuse beyond a reasonable doubt. Accusations were brought when his daughtered recovered memories of abuse. The daughter’s trauma was described as “so great that she was unable to remember for eight years—and then only after months of therapy” (McCartan). Her memories were corroborated by her childhood medical records – as well as Wilson’s repeated sexual relations with teenage babysitters and advances towards church minors. 
People v. Lynch: William Lynch was “[c]harged with 14 counts of lewd conduct with a child stemming from alleged attacks on four women when they were between 7 and 13 years old from March, 1967 to July, 1972.” One of the women repressed the memory, recovering details of the event that occured after seeking therapy for severe depression. Two of the other women, her sisters, had remembered the abuse ever since. 
There is some evidence that memories recovered outside of therapy (having never seen a therapist, or having recovered memories before seeing a therapist) are more likely to have corroborating evidence . However, the likelihood of corroboration does not indicate whether the memory is accurate, and the lack of corroboration does not necessarily mean a memory is inaccurate or false.
It is true there are therapists, no matter how well intentioned, who practice bad or suggestive therapy. They are not representative of all therapists who treat patients experiencing recovered memories. Distrust in recovered memories due to the role of suggestion should depend on what happened during the specific course of therapy – not due to the presence of therapy itself.
Critics of recovered memories often overstate the role of suggestion in therapy. For example, Pamela Freyd, the founder of the False Memory Syndrome Foundation, describes her daughter’s memories of abuse as “therapist elicited.”  However, her daughter reports that she saw her therapist once before recovering memories outside of the therapist’s office. 
 Bodkin, Alexander. (1994, October). Is It Worth The Risk? FMS Foundation Newsletter. 3(9), 7.
 Canter, D. (2003). Yes, I remember it well. New Scientist 178(2399) p. 54. [Review of Remembering Trauma by Richard McNally].
Cited in Sidebar (2003, July/August) FMS Foundation Newsletter. 15(5), 6.
 Dalenberg, C. J. (1996). Accuracy, timing and circumstances of disclosure in therapy of recovered and continuous memories of abuse. Journal of Psychiatry & Law, 24(2), 229–275.
 Leavitt, F. (1999). Suggestibility and treatment as key variables in the recovered memory debate. American Journal of Forensic Psychology, 17, 5-18.
 McCartan, M. (1991, February 17). 'Daddy Hurts Me'... The Horror of Incest. Des Moines Register.
 Tamaki, Julie. (1994, May 15). Abuse Case to Challenge New Law on Limitations. Los Angeles Times, B1. https://www.latimes.com/archives/la-xpm-1994-06-11-me-2979-story.html)
 Geraerts, E., et al., (2007). The Reality of Recovered Memories: Corroborating Continuous and Discontinuous Memories of Childhood Sexual Abuse. Psychological Science, 18(7), 564–568.
 Doe, Jane (1991, Summer). How Could This Happen? Coping with A False Accusation of Incest and Rape. Issues In Child Abuse Accusations, 3(3).
Author identified in Freyd, Pamela. (1991, November 15). I am “Jane Doe.” Letter to Carole Roscielny.
 Heaney, K. (2021, January 6). The Memory War Jennifer Freyd accused her father of sexual abuse. Her parents’ attempt to discredit her created a defense for countless sex offenders. The Cut. https://www.thecut.com/article/false-memory-syndrome-controversy.html