top of page

“These cases are just like the daycare abuse cases.”

“Now, there are hopeful signs that this insanity is coming to an end. Many of the worst day care cases have been overturned, and innocent people have been released from prison. Many families are being reunited as their children come to realize that the, quote, "memories," were false of events which never occurred.” - Mark Pendergrast, at the FMSF Day of Contrition Conference. [1]

“Suggestion is the true common denominator. Why? Because prosecutors who are interrogating children... in an illegitimate fashion are suggesting to them the answers that they want them to produce, and when psychotherapists who would build a practice around recovered memory gradually convince their clients that they were sexually abused in childhood, it is suggestion that they are using” - Richard Gardner, at the FMSF Day of Contrition Conference. [2]


Proponents of this argument often claim that cases of childhood sexual abuse in daycares and cases of recovered memories are linked by the use of suggestion, which produces false memories of abuse – the result of the mass hysteria discussed in the previous argument. However, it is important to consider the following:

Daycare cases often involve children with continuous memory of abuse, who bring forward accusations independent of therapeutic influence, and who did not experience repression or recovery of their memories. Furthermore, investigations into daycare cases are often spurred by a child’s spontaneous disclosure of a compelling statement. In this way, cases of daycare abuse are unrelated to the debate surrounding recovered memories, and cannot be dismissed with the same arguments used to dismiss recovered memories.

The roles of suggestion in both daycare cases and recovered memories are often overstated and under-evaluated. Examples of highly-publicized cases and relevant studies follow:
1. Richard Gardner, quoted above ascribing cases of daycare abuse to falsely-implanted suggestions, appeared as an expert witness for the defense in Kelly Michaels’ daycare abuse case. Gardner once wrote: "After examining the alleged victims, the accusing parents, and Ms. Michaels, I was convinced she did not engage in the variety of abominable acts attributed to her." This was not true. Gardner actually evaluated only two of the twenty children, and none of the parents. Furthermore, Gardner never acknowledged the spontaneous disclosure of abuse that began the investigation into this case. Without thorough and proper investigation, Gardner dismissed the children’s accusations of abuse as false memories implanted by suggestion. [3]
2. Pamela Freyd, the founder of the False Memory Syndrome Foundation, describes her daughter’s memories of abuse as “therapist elicited.” [4] However, her daughter reports that she saw her therapist only once before recovering memories outside of the therapist’s office. [5]
3. Elizabeth Loftus has been the subject of multiple ethics complaints for falsely characterizing cases as involving unreliable and implausible recovered memories implanted by suggestive therapists. [6] In one example, Jennifer Hoult attests to how Loftus falsely claimed Hoult only remembered abuse after entering therapy, altered evidence about Hoult’s therapy to claim her therapist implanted memories of abuse with suggestion, and altered the content of Hoult’s memories to seem implausible. [7] These are a few examples of false characterization by Loftus, and a full description of the specific misrepresentations of fact in the Hoult vs. Hoult case can be found here:
4. Laboratory experiments on suggestive interviewing techniques by Stephen Ceci became a “staple in… defense briefs in child molestation cases” [8]. The findings of this study were overstated and underevaluated in court cases concerning child abuse and prominant news sources. Ceci described his experiments as “a pale version of what happens in real cases. It doesn’t come close, for example, to what was done in the Kelly Michaels case.” [9] However, the Michaels case was much less suggestive than his laboratory work – children were interviewed for 10-12 consecutive weeks, where children in the Michaels case were interviewed a maximum of three times. Furthermore, “The questions [asked in laboratory experiments] were not merely “suggestive”; they actually contained declarative statements. The children were told repeatedly over time that Sam Stone had done specific acts… No child in the Michaels case was subjected to such questioning by investigators.” [8] “Children were not told by interviewers that Kelly Michaels had committed specific acts of sexual abuse, let alone week after week.” [8]. A follow up study evaluating Ceci’s work undercut his strongest claim – that the implanted false memories were permanent. The child who recounted the suggested event in great detail later admitted that it was “just a story.” [10]
5. As mentioned in previous arguments, a small percentage of recovered memories are recovered in therapy [11], and those that are have been found to be just as reliable as memories recovered outside of therapy. [12] In large populations of women who repressed and recovered memories of previously documented sexual abuse, it was found that there was “no evidence from this study of child sexual abuse experienced by this community sample of women that recovery of memories was fostered by therapy or therapists.” [13]
6. Ralph Underwager and Hollida Wakefield are two researchers who produced a body of work regarding interview suggestibility of children in cases of sexual abuse. Their research has often been cited in court cases concerning daycare abuse to critique the accuracy of children’s accusations, and Underwager himself often testified as an expert witness for the defense. However, when his writing was critically reviewed by Anna Salter, it was found that there were an “extraordinary number of distortions and errors” in his work. [14]

The similarities between daycare abuse and recovered memory cases begins and ends with those who use suggestion to discredit the narratives of childhood abuse victims.

Furthermore, the suggestive interviewing tactics purported to cause false memories have been used by the very people who condemn them, in hopes of getting the accuser to deny or retract their allegations of abuse. You can read more about specific instances at our [suggestive interviewing techniques] page.


[1] Pendergrast, Mark. (1997, January 14). Don’t Demonize: A Message Of Compassion And Hope. [Conference Presentation]. Day of Contrition Revisited, Salem, MA, USA.

[2] Gardner, Richard. (1997, January 14). The Spin-Off of Daycare Hysteria: Epidemic Accusations of Sexual Abuse in Custody Disputes. [Conference Presentation]. Day of Contrition Revisited, Salem, MA, USA.

[3] Gardner, Richard. (1993, March 1). Apparatchiks Turn ‘Child Abuse’ into ‘Witch Hunt.” New Jersey Law Journal, 17.
It turns out Gardner exaggerated when he said, “After examining the alleged victims, the accusing parents, and Ms. Michaels, I was convinced that she did not engage in the variety of abominable acts attributed to her.” Aware that few children and no parents were examined in the civil cases, I wrote Dr. Gardner and inquired about how many children and parents he interviewed. His response indicates he “only evaluated two children” and that he did not evaluate any parents. Correspondence from Richard Gardner to Ross Cheit, September 6, 2001.

[4] 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.

[5] 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.

[6] Landsberg, Michele. (1996, February 11). Beware of false prophets peddling false-memory hype. Toronto Star. A2.

[7] Hoult, Jennifer. (2005 & 2014). "Remembering Dangerously" & Hoult v. Hoult: The Myth of Repressed Memory that Elizabeth Loftus Created. Consider the Evidence for Elizabeth Loftus' Scholarship and Accuracy.

[8] Cheit, R. E. (2014). The witch-hunt narrative: Politics, psychology, and the sexual abuse of children (pp. xx, 508). Oxford University Press.

[9] From the Mouths of Babes. (1993, October 22) ABC News 20/20, 3.

[10] Huffman, M. L., Crossman, A. M., & Ceci, S. J.. (1997) ‘Are False Memories Permanent?’: An Investigation of the Long-Term Effects of Source Misattributions. Consciousness and Cognition 6, 482–490, 488.

[11] Elliott, D. M. (1997). Traumatic events: Prevalence and delayed recall in the general population. Journal of Consulting and Clinical Psychology, 65, 811-820.

[12] 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.

[13] Williams, L. M. (1995). Recovered memories of abuse in women with documented child sexual victimization histories. Journal of Traumatic Stress, 8, 649-673.

[14] Salter, A. (1992). Accuracy of expert testimony in child sexual abuse cases: A case study of Ralph Underwager and Hollida Wakefield. Unpublished manuscript.

bottom of page