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What FMSF said they did:

“Psychotherapy is an essential service and people who need that service should be assured of quality care. The concern of the Foundation is that all mental health professionals are being tainted because of the misguided practices of Some.” - Pamela Freyd, in the FMSF Newsletter. [1]

“We do not condemn all of psychotherapy. We consider psychotherapy to be a needed public service just as medical systems are.” - Pamela Freyd, in the FMSF Newsletter. [2]

What FMSF actually did:

✓ + Discredited therapy as a whole, supported legislation that gutted therapeutic confidentiality and challenged basic therapeutic principles.

From the start, the FMSF identified therapists as the culprit of the false memory “epidemic.” They described therapists as “cult-like,” claiming they indoctrinated daughters with false beliefs and induced accusations of sexual abuse. [3]

“Many of the efforts of the Foundation (including mine) have been directed towards trying to educate, exhort, regulate or sue therapists into accepting more professional responsibility for the influence they exert over their patients.” - Spencer Morfit, in FMSF Newsletter. [4]

A 2004 FMSF newsletter column titled “The Key to Our Solution” reads: "The medical/psychology industry is a commercial enterprise. They are not your friends, and I do not think that their first priority is your child. Their first priority is to make money and, in my opinion, you and your problems are a distant second.” [5]

Because of the hostile attitude towards therapy, Stephanie Dallam writes that “False memory rhetoric has also had a chilling effect on the willingness of therapists to believe and appropriately treat abuse survivors... Because of the risk of being charged with implanting false memories, some insurance providers are advising practitioners to refuse to take clients who allege delayed recall.” [6]

Lobbying Efforts Against Therapy
Key members of the FMSF in administrative positions formed a secondary lobbying organization out of the Illinois FMSF office, advertised to and composed of FMSF members. [7] Through this, the FMSF attempted to introduce legislation targeting therapists and therapy as a whole:
Confidentiality: Currently, therapists are required to breach confidentiality if they believe serious and imminent harm will come to the patient or other person(s). The proposed legislation would require therapists to share confidential information if the patient had any history of childhood abuse – allowing incestuous parents to request their children’s therapy records at will. [8]
Third Party Lawsuits: This legislation would specifically permit third parties (i.e. people other than the patient) to sue therapists, with a lengthy statute of limitations. [9] An article published in the Harvard Law Review concluded that “the legal system should not permit third-party liability against the wishes of the therapist’s client” as there is no precedent for such third-party liability, and that clients suing their therapists directly was an adequate route to address malpractice. [10]
Inordinate Restrictions: Therapists would only be allowed to practice techniques that are scientifically valid under the criteria used for physical sciences (eg. physics, biology, chemistry). The impossibility of such a requirement would render most (if not all) mainstream psychotherapeutic treatments illegal, even though they are well supported by clinical data and are considered clinically valid. [8]

Read more about the FMSF’s lobbying efforts against therapy on our [Lobbying Page].

✓ + Lead Targeted Harassment Campaigns against Therapists, and Encouraged Families to Harass their Daughters’ Therapist.

“Have you had any experience that might aid others in penetrating the screen of "professional confidentiality?" Do you know ways of determining who this [therapist] might be when we parents have no clue? Please write to FMSF. We need to compile a plan that will enable us to be effectively proactive in our efforts to unite our families.” - FMSF Staff, in the FMSF Newsletter. [11]

In a column titled “What Can Families Do?” the FMSF Staff wrote “Some parents have told us that they hired private detectives to find out the names of those responsible for rewriting their children's history.” and “Some families have… picketed a therapist's office.” [12]

“You have filed complaints; you have appeared in public… you have even picketed;” “You are changing the climate. Keep it up. We will do our part from the office, but the ending depends on you.” - Pamela Freyd, FMSF Newsletter. [13]

The Case of David Calof & Chuck Noah
David Calof, a leading clinician in the treatment of childhood trauma, was subject to a targeted harassment campaign run by Chuck Noah, the primary contact and “volunteer coordinator” for the Seattle FMSF branch. [14] Calof did not treat Noah, his family members, or anyone from a family involved in the local FMSF.

Calof's patients were videotaped while entering and exiting his building, he received numerous threatening phone calls, and his office was picketed for months. The picketers bore signs with malicious slogans such as “Pseudo Therapist creates victims for profit!!” “David Calof Sexploits Women,” and “Beware Calof’s Crooked Femi-Nazi Pow [sic] lies.”[14] The latter depicted two red Swastikas. The picketers maintained a near constant presence by coordinating shifts, and spread up to three city blocks. [14]

Previously, Noah had picketed his daughter's therapist, only being deterred after they filed two anti-harassment orders against him. [14]

The FMSF was supportive of the Seattle picketing effort:
Descriptions of the picketing tactics were posted in their “Make a Difference” newsletter column as an example for readers to emulate. [15]
Pamela Freyd has described Chuck Noah as “one of the "important people" in the FMS movement,” and a “noble man.” [14]
Pamela Freyd falsely claimed to speak with Calof’s phone company in order to deny that FMSF members were threatening Calof over the phone. She widely distributed this information, giving Chuck Noah “evidence” to present in court that he did not harass Calof. [14]

Read more about the situation on David Calof’s Page.

✓ + Encouraged Third Party Lawsuits against Therapists

“Third party standing represents the major hurdle that aggrieved family members must overcome in order to seek relief in the courts.” - James Simons, FMSF Staff Member, in the FMSF Newsletter. [16]

Many FMSF members were parents who blamed therapists for implanting ‘false memories’ in their daughters and spurring accusations of childhood abuse. Many of them “sought revenge” [7] against these therapists - but were unable to sue. Legally, therapists only have a duty to their patient – they have no duty to people not directly receiving healthcare. Regardless of ‘emotional injury,’ the parents could not receive compensation for damages.
Thus, the FMSF contended that third parties (people other than the patient, i.e. parents) should be allowed to sue therapists through ‘Third-Party Lawsuits.’ The FMSF’s secondary lobbying organization attempted to introduce legislation that specifically permitted third parties to sue therapists, with a lengthy statute of limitations. [9] In their monthly newsletter, the FMSF encouraged families to sue therapists, authored amicus briefs arguing that therapists have a duty to third parties [17], reported on third-party lawsuits, and celebrated when a therapist was successfully sued [18]. The FMSF provided “A Legal Resource Kit has been available from the foundation since August… The Kit also includes sample filings from a third party suit against therapists/clinics.” [19]

After an unprecedented California case where Gary Ramona sued his daughter’s therapist, Bowman and Mertz published an article in the Harvard Law Review specifically analyzing the impacts of third party lawsuits against therapists on legal and public policy. They found that in an analysis of California courts’ history expanding third-party tort liability, the Ramona case was “atypical” and an “aberration even within California law.” They found no adequate precedent for the third-party responsibility imposed in Ramona, describing the case as a “major diversion from the current state of tort law.” [10]

The authors concluded that “the legal system should not permit third-party liability against the wishes of the therapist’s client” and that “the courts should not allow malpractice claims when fully competent adult patients or clients do not believe they have suffered malpractice.” [10]

Mertz and Bowman assert that an “powerful and adequate” route to address malpractice is through the client themselves suing the therapist, which restores “agency and primary decision making authority” to the patient. They note that people who have retracted allegations of abuse have brought successful suits against negligent therapists. [10]

By allowing family members to sue therapists against the wishes of the client, it “Robs adult clients of a voice in crucial decisions regarding their own therapies and hence their personal lives,” and would allow family members accurately accused of abuse to disrupt the therapeutic process. Bowman and Mertz note that “It is virtually impossible to continue a therapeutic relationship when its very substance has become the subject of public litigation.” [10]

If family members believe that they have been harmed by false allegations of abuse, they should “address their problems directly with the adult women and men involved,” and if pursuing legal action, file a defamation or malicious prosecution suit. [10]

In response to Bowman and Mertz publishing in the Harvard Law Review, Elizabeth Loftus and Moira Johnson called the article the “satan of today” and a “very scary document” at an FMSF sponsored conference. [20]

✓ + Exaggerated the presence and negative impact of therapists in recovered memory cases.

The FMSF often broadly describes false memories as recovered ‘during therapy’; In a column titled “Thoughts on Sex Abuse Statistics” the FMSF staff laments that “It is
clearly not politically correct to question... women who say they are survivors of [childhood sexual abuse] but who never remembered it until they were in therapy.” [21] The FMSF consistently argued that therapists are directly responsible for the creation of false memories, targeting specific “memory enhancement techniques” therapists use during sessions to elicit memories. Alongside descriptions of “cult-like” therapists who exert “power” [22] over their clients, it’s implied that memories described as ‘recovered in therapy’ were recovered under the direct influence of a therapist during a therapy session.

However, survivors' memories are often described as ‘recovered in therapy’ by the FMSF, even if the recovery happened outside the therapist’s office or before the individual contacted a therapist.

Johnson v. Rogers Memorial Hospital
In Johnson v. Rogers Memorial Hospital, the Johnsons sued three therapists that treated their adult daughter, Charlotte, who was not party to the suit. The lawsuit was in response to Charlotte’s accusations of abuse against both of her parents, which was allegedly based on recovered memories of abuse. [23]

Often while speaking for the FMSF, Pamela Freyd described Charlotte’s memories of abuse as induced by the three therapists. In the Wisconsin State Journal, she stated that the therapists “use[d] a variety of dubious techniques, including hypnosis, to try to excavate supposedly repressed memories.” [24] In the Winter 2011 FMSF newsletter, she writes that the case is a “symbolic win for all families who believe that their children were harmed in therapy that focused on excavating memories.” [18] Later, in the Spring 2011 newsletter, Pamela Freyd rejoices over the “exposure of [Charlotte’s] negligent therapists and the bankrupt theory on which their practice rested,” [25] implying that the therapists practiced based on the non-existent theory of ‘Recovered Memory Therapy.’

In actuality, Hollida Wakefield, the primary expert witness for the Johnsons and FMSF advisory board member, admitted that the therapists “didn’t actively try to get her to recover memories,” that they did not use hypnosis, that there was no “digging for memories,” and that there was no evidence that the therapists planted any memories of abuse. [26] In short, there was no evidence that the memories in this case were caused or created by therapy.

Hoult v. Hoult
Elizabeth loftus, a FMSF scientific advisory board member described by Pamela Freyd as “a highly visible proponent of positions held by the Foundation” [27] was an expert witness for the defense and frequently summarized ‘false memory’ cases in the FMSF newsletter, FMSF conferences, and for the media.
Loftus was subject to an ethics complaint by Jennifer Hoult concerning her case, Hoult v. Hoult. Loftus wrote about the Hoult v. Hoult case, despite the fact that she was legally uninvolved with the case. Jennifer Hoult demonstrated that Loftus overemphasized the role of therapy in memory recovery in an attempt to characterize the memories as unreliable and induced by a therapist. This included: altering the historical sequence of trauma and symptom manifestation to falsely claim they occurred after two years of therapy, claiming that Hoult’s therapist was paid to acquire memories of trauma, and omitting that Hoult recovered memories of trauma at home. [28]

You can read more about this case on Hoult’s website or on Elizabeth Loftus’ page.

Jennifer Freyd
Pamela Freyd wrote about her daughter’s accusation of abuse in an anonymous letter “How Could This Happen? Coping with A False Accusation of Incest and Rape,” later identifying herself as the author and Jennifer Freyd as the daughter. Pamela Freyd described her daughter’s memories as “therapist elicited ‘repressed memories’ of the abuse” and that “the therapy was based on the premise that… the therapist must help the patient uncover these memories.” She stated “I am angry with… the training and certification of my daughter's therapist — training that has resulted in Susan being in the terrible position that she is now.” Pamela Freyd attributed her daughter’s memories, disposition, and actions to a therapist looking to purposefully uncover memories. [29]

However, Jennifer Freyd attests that her therapist had little to do with her memory recovery. The topic came up only once prior to her realization, when during the second session of the intake process, her therapist asked her if she had been abused. She said no. Jennifer Freyd began to remember her abuse outside of her therapist’s office, prompted by a holiday visit from her parents. In short, her therapist did not elicit, uncover, or purposefully search for Jennifer Freyd’s memories of abuse. [30]

✓ + Coined and targeted “Recovered Memory Therapy:” a practice that didn’t exist.

Recovered memory therapy (RMT) was loosely defined by the FMSF and its advisory board. No clinician used the term to describe themself or their therapy practice, the term was coined by FMSF proponents to describe others. Definitions of RMT describe therapists who “maintain that patients often carry buried memories” and that “unearth[ing] these repressed memories can cure the disorder the patient presents.” These therapists suggest false memories to their clients, “producing what they expect to find.” [31] Despite this seemingly clear-cut set of ideas, it’s stated that “recovered memory therapy can be found in… two hundred talk therapies that populate our social landscape” [32] and is “a hodge-podge of techniques varying with each therapist.” [33]

From these definitions, it’s clear that RMT depends on the intent of the therapist, rather than what happens in therapy – no specific school of therapy or particular set of techniques intrinsically makes up a ‘Recovered Memory Therapist.’ Despite this, the FMSF consistently attacks specific techniques they deem “Recovered Memory Techniques.” In the FMSF newsletter, over 30 ‘techniques’ were alleged to generate false memories, including massages, journaling, reading self help books, and group therapy. Furthermore, simply receiving therapy using any ‘RMT technique’ was enough for the FMSF to write off someone’s memories as “therapist elicited.”

To date, there is no study that specifically assesses whether these techniques actually create false memories in patients. Similarly, if these techniques do create false memories, no study has assessed how often they do so, to what degree, or the circumstances that lead to these techniques creating false memories. The FMSF’s list of ‘RMT techniques’ is sourced from surveys sent to accused parents who pay the FMSF membership dues. [34]

The wide variety of techniques claimed to create false memories and the inability to empirically assess a therapist’s intent meant that nearly anyone who recovered memories remotely associated with therapy – either with a therapist, at home outside of a session, or after the conclusion of therapy – could be described by the FMSF as having undergone RMT, regardless of whether therapy had an impact on their memories or not.

Members of the FMSF advisory board have claimed at FMSF conferences that over 1 million therapists practice ‘recovered memory therapy,” [35] a number large enough that it implies most people with recovered memories have been influenced by recovered memory therapy. This extraordinary claim has been thoroughly debunked, demonstrating how the term has been incorrectly overapplied by FMSF proponents to instill caution in the institution of therapy.

While it is undeniable that harmful, abusive, and suggestive therapy exists, there is no empirically defined category of therapists practicing ‘Recovered Memory Therapy.’ The term was created by FMSF proponents to discredit the memories of anyone associated with therapy.

For a detailed analysis of this topic, see our page on [Recovered Memory Therapy].


[1] Freyd, Pamela. (1995 June 1). Dear Friends. FMS Foundation Newsletter. 2(6), 1.
[2] Freyd, Pamela. (1996, July/August). Dear Friends. FMS Foundation Newsletter. 5(1), 1.
[3] FMSF Staff. (1993, October 1). Is FMS A New Phenomenon? FMS Foundation Newsletter. 2(9), 6.
[4] Morfit, Spencer. (2004, July/August). Essay on Personal Responsibility. FMS Foundation Newsletter. 13(4), 5.
[5] “Proud Parent and Grandparent” (2004, September/October). FMS Foundation Newsletter. 13(5), 10.
[6] Dallam, Stephanie. (2002). Crisis or Creation: A systematic examination of false memory claims. Journal of Child Sexual Abuse,9 (3/4), 9-36.
[7] Ohme, Herman. (2002, March). It felt something like the WTC Towers 9-11 attack. Ohio Association of Responsible Mental Health Practices (OARMHP) Newsletter.
[8] Simon, Judith. (1995). The Highly Misleading Truth and Responsibility in Mental Health Practices Act: The “False Memory” Movement’s Remedy for a Nonexistent Problem. Moving Forward, 3(3), 12-21.
[9] Quirk, Sherry & DePrince, Anne. (1995). Backlash legislation targeting psychotherapists. The Journal of Psychohistory, 22(3), 258. Retrieved from
[10] Bowman, Cynthia & Mertz, Elizabeth. (1996, January). A Dangerous Direction: Legal Intervention in Sexual Abuse Survivor Therapy. Harvard Law Review. 109 (3) pp. 549-639.
[11] FMSF Staff. (1993, April 6). Case of the Missing Therapist. FMS Foundation Newsletter. 2(4), 1.
[12] FMSF Staff. (1992, October 5) What Can Families Do? FMS Foundation Newsletter. 1(9), 4.
[13] Freyd, Pamela. (1992, October 5) Dear Friends. FMS Foundation Newsletter. 1(9), 1.
[14] Calof, David. (1998). Notes From a Practice Under Siege: Harassment, Defamation, and intimidation in the Name of Science. Ethics & Behavior, 8(2), 161–187.
[15] FMSF Staff. (1994, November/December). Make a difference. FMS Foundation Newsletter. 3(10), 8.
[16] Simons, James. (1994, September). Public Policy and Third Party Standing in Texas. FMS Foundation Newsletter. 3(8), 16.
[17] Freyd, Pamela. (1995 June 1). Dear Friends. FMS Foundation Newsletter. 2(6), 1.
[18] FMSF Staff. (2011, Winter). Johnsons Awarded $1 Million in Epic Wisconsin Case. FMS Foundation Newsletter. 20(1), 6-10.
[19] FMSF Staff. (1993, November 3). FMSF Legal Research Project. FMS Foundation Newsletter. 2(10), 1.
[20] Loftus, Elizabeth. (1997, January 13). Forum B: Social Science Issues. [Moderator Commentary]. Day of Contrition Revisited, Salem, MA, USA.
[21] FMSF Staff (1993, April). Thought on Sex Abuse Statistics. FMS Foundation Newsletter. 2(4), 5-6.
[22] Freyd, Pamela. (1993, October). Dear Friends. FMS Foundation Newsletter. 2(9), 1.
[23] Johnson v. Rogers Memorial Hospital. (2005). 283 Wis. 2d 384 pg 448.
[24] Erickson, Doug. (2011, January 23). Parents Awarded $1 Million in Suit Claiming Therapists Created False Memories of Abuse. Wisconsin State Journal.
[25] Freyd, Pamela. (2011, Spring). Dear Friends. FMS Foundation Newsletter. 20(2), 1-2.
[26] Wakefield Deposition (January 20-21, 2010), pp. 172-174, 217, and 233.
[27] Freyd, Pamela. (2004, May/June). Dear Friends. FMS Foundation Newsletter. 13(3), 1-2.
[28] 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.
[29] 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.
[30] Freyd, Jennifer & Birrell, Pamela (2013). Blind to Betrayal: Why We Fool Ourselves We Aren't Being Fooled. Wiley.
[31] FMSF Staff. (1993, November 3). How Could This Have Happened To My Child? Mind Control? FMS Foundation Newsletter. 13(3), 3-4.
[32] Ofshe, R., & Watters, E. (1994). Making monsters: False memories, psychotherapy, and sexual hysteria. Charles Scribner's Sons/Macmillan Publishing Co. pg. 1.
[33] Hochman, John. (1994). Recovered Memory Therapy and False Memory Syndrome. Skeptic Magazine. 2(3). 58-61
Featured in: “Attention Readers:” (1994, May 4). FMS Foundation Newsletter. 3(5), 13.
[34] FMSF Staff. (1992, May 1). Responses About Therapeutic Techniques. FMS Foundation Newsletter. 1(4), 2.
[35] Pendergrast, Mark. (1997, January 14). Don’t Demonize: A Message Of Compassion And Hope. [Conference Presentation]. Day of Contrition Revisited, Salem, MA, USA.

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