The most distinguished female psychologist of the 20th century—whose pioneering research discredited the “archival” model of human memory and established our understanding of memories as malleable rather than fixed—was canceled in 2020. Elizabeth Loftus had appeared before a Manhattan court to describe “the misinformation effect” and the ease with which false memories can be implanted “in the minds of otherwise ordinary, healthy people”—concepts that typify her body of research, hardly news to her colleagues at the University of California, Irvine, or her peers in the National Academy of Sciences. But this time, she had spoken as a witness for the defense in The People of New York v. Harvey Weinstein. A scheduled talk at the New York University psychology department was called off. A colleague at Irvine demanded, “Harvey Weinstein—how could you?” Irvine law students generated a petition decrying Loftus’s efforts “to further traumatize and disenfranchize survivors” and demanding that the administration “address the acute problem of Elizabeth Loftus.” The New Yorker observed that, however authoritative, Loftus’s body of research “collides with our traumatic moment.”
“The memory wars seemed to have concluded with the victory of the skeptics.”
It wasn’t the first time Loftus had challenged a politically privileged account of traumatic memory. In the 1990s, she was a leading figure in the long-fought “memory wars” that pitted psychiatrists and accused parents on one side against clinicians and victims’ advocates on the other. The two camps contested the validity of “repressed” and “recovered” memories of trauma, especially those elicited in sessions of evocative psychotherapy. Launched in the early 1980s and fought in the popular media and the courts, featuring national panics and scandals as well as thousands of unpublicized battles, the memory wars seemed to have concluded with the victory of the skeptics, such that Johns Hopkins psychiatry chief Paul McHugh could write in 2003, “The repressed-memory diagnosis has finally been repressed.”
Nearly 20 years later, the repressed has returned. #MeToo has touched off pop-scientific discussions of the nature of traumatic memory, most notably during legal and pseudo-legal proceedings against Weinstein and Brett Kavanaugh; if one is to #BelieveWomen, affirming the validity of recovered memory turns out to be quite necessary. Preceding #MeToo by a few months, The Keepers, an acclaimed true-crime documentary on Netflix, anticipated the way in which old accounts of traumatic memory were to comport with new feminist cultural theses. Bessel van der Kolk, an influential theorist of recovered memory, appeared last fall on The Ezra Klein Show to receive praise for his perennially popular 2014 book (still No. 1 on the New York Times paperback nonfiction list as of this writing) on the psychological and physiological effects of repressed traumatic memories. Most important, in the everyday work of legions of American psychologists and social workers, the practice of recovered-memory therapy has quietly persisted.
Frederick Crews, an ex-Freudian literary critic who in the mid-1990s assailed recovered memory in a celebrated series of essays for the New York Review of Books, has observed these developments closely. “Looking back with chagrin,” he tells me, “we can see that the flame of recovered memory was suppressed, not extinguished.” The therapy’s academic, clinical, and institutional persistence had hardly been touched by the victories of the skeptics in high-profile contests. This persistence has eroded the skeptics’ success in the legal arena, and in the news and entertainment media the popular tropes of traumatic-memory mythology retain their appeal. Fabulous tales of sadistic conspiratorial abuse, and the esoteric psychodynamics that supposedly conceal and then reveal them, have found a new audience—an upscale, high-information, politically conscientious audience.
Recovered memory has once again met with a congenial sociopolitical moment. This moment is different from that of the early 1980s. Then, affirmations of recovered memory might and did comport with most any cultural politics; today, we are observing recovered memory’s ideological purification. What the capaciousness of the earlier movement concealed, today’s narrowing makes clear: There is always ideology at work in valorizations of traumatic memory. For rhetoric, clinical practice, and legal contention have all urged the exemption of this class of memory from ordinary standards of what is probative, plausible, or even possible. As Harvard psychiatry professor Judith Herman urged before the American Psychiatry Association in 1994, the practitioner of recovered memory therapy makes belief, rather than an inquiry after truth, his business in the determination of right and wrong.
The prehistory of the memory wars begins in 1893-95, with Freud’s formulation, application, and rejection of his “seduction theory.” On this theory, the psychological symptoms of his mostly female, mostly bourgeois patients were the result of the psyche’s labor in repressing consciousness of incestuous abuse sustained in early childhood. Famously—soon enough infamously—Freud discarded seduction theory, having found it unprovable and clinically useless. He resorted to its subtler cognate, the theory of infantile sexuality, according to which all our ills arise from the repression of urges that conflict with society (such as the urge to commit incest with one’s parents). As Philip Rieff was to observe, much the same cultural polemic is encoded in both theories: Both partake of “that dualist tradition which pits human nature against social order.”
Accordingly, many mental-health practitioners trained in the orthodox Freudianism of infantile sexuality switched easily to an updated version of his seduction theory in the late 20th century. The distinctive diagnosis of the 1970s was multiple personality disorder, understood as the splitting of the psyche into “alters” as a defense against traumatic memory. The theory of MPD received clinical application in certain psychiatric wards and gained popular legitimacy through best-selling books, such as Flora Rheta Schreiber’s Sybil: The Classic True Story of a Woman Possessed by Sixteen Separate Personalities (1973), and the television film based on it (1976).
Attention shifted in the 1980s to evocative psychotherapy, the technique used to recover these pathogenic memories. Again, the decade’s emphasis was heralded by a best-seller: Lawrence Pazder and Michelle Smith’s Michelle Remembers (1980), the purportedly true story of the physical and sexual abuse Smith had endured during Satanic rituals, memory of which she had repressed, then recovered with the aid of hypnosis. The practice of evocative psychotherapy became widespread during the 1980s, in part because it requires no serious training or certification, unlike the arcana of orthodox Freudian analysis. And it accords with the cultural politics of the type of person likely to become a therapist or a social worker: romantically left-tending, suspicious of society and the family as a conspiracy against the authentic and vulnerable (feminine or child) self.
This complex of attitudes was clarified in 1984 by Jeffrey Moussaieff Masson, renegade archivist of the Freud papers, who argued in The Assault on Truth that Freud had suppressed the seduction theory not because it had failed, but because he had found it all too true: It entailed the exposure of powerful men whose support he required. Freud thereby betrayed generations of women, whose traumas go unrecognized even by themselves. Masson’s argument, panned by orthodox Freudians but eagerly received by many feminists, demonstrated the anti-patriarchal polemic inherent in seduction theory and its 20th-century iterations. Four years later, the self-help best-seller The Courage To Heal, coauthored by two feminists untrained in psychology or any related field, taught thousands of women how to be sex-abuse victims. Lacking consciousness of abuse was no impediment. “You may think you don’t have memories,” Ellen Bass and Laura Davis assured their readers, “but often as you begin to talk about what you do remember, there emerges a constellation of feelings, reactions, and recollections that add up.” The Courage To Heal would go through many printings and editions and incite untold incest allegations.
“No catacombs were ever discovered, no wizards’ robes, no pornographic photos.”
The Courage To Heal launched the recovered-memory movement as a true mass movement. But by the year of The Courage To Heal’s first run, a counter-movement had begun to form. The McMartin Preschool case, begun in 1983, was falling apart by the end of the decade; the testimony of its many alleged victims, obtained through leading interviews and suggestive therapy, was proving impossible to substantiate. Dozens of children alleged that a “ring” of adults had subjected them to sexual abuse in the course of magic rituals conducted in secret tunnels beneath the preschool (or in secret rooms to which the children were delivered by being flushed down the toilet, or at nearby carwashes or airports, or in out-of-state national parks reached by hot-air balloon). The McMartin case thus established the template for daycare and Satanic ritual-abuse panics. But no catacombs were ever discovered, no wizards’ robes, no pornographic photos. McMartin and its several copycat cases attracted initial credulous attention from newspapers and television shows; then, as the dizzying numbers of charges against dizzying numbers of defendants were dropped, it tended to the discrediting of all such cases. What Ross Cheit, a professor of political science, calls “the witch-hunt narrative” emerged as the popular take, banishing “We believe the children.”
This shift in the narrative didn’t prevent recovered-memory therapy from being practiced in therapists’ offices across America. But it did give skeptics a chance to be heard. Accused parents formed the False Memory Syndrome Foundation, an advocacy group that by the end of the 1990s would receive requests for aid from more than 25,000 American families. The FMSF empaneled a board of memory experts, including Loftus, McHugh, Crews, and Harvard psychiatrist Richard McNally. In one criminal case after another, expert witnesses dispatched by the FMSF challenged the admissibility of uncorroborated recovered memories.
In 1996, the skeptics won a so-called Daubert ruling in New Hampshire v. Hungerford, according to which defense attorneys may demand a pretrial hearing concerning the scientific validity of recovered memories for any criminal case based solely on recovered memories. (Today, federal courts and most states operate under the Daubert standard for admissibility of expert witness testimony, such as that on behalf of recovered memory; a few states, such as California, Pennsylvania, and Washington, retain the older and looser Frye standard. The validity of recovered memory is more easily challenged in Daubert states than in Frye states.) Short of a ruling that all such evidence was always inadmissible, this was as much as skeptics could hope for. The outcome, combined with another development in the civil courts—the success of several multimillion-dollar lawsuits against therapists and hospitals by recovered-memory “retractors”—allowed the skeptics to declare victory in the memory wars. Their experts had prevailed in the courts of law and the court of public opinion, and they expected that their achievements would be transferable to other arenas. “It seemed reasonable to infer that the psychotherapeutic profession had learned a permanent lesson,” Crews tells me. “We critics of the movement assumed that recovered memory would soon be a thing of the past.”
Were the memory wars a culture war? Not in any simple sense. Despite the feminist polemic implicit in seduction theory and articulated by lay leaders of the recovered-memory movement, one could not, in the 1980s and ’90s, expect affirmers of recovered memory to be leftists or liberals and skeptics to be traditionalists or conservatives. For cultural conservatives could find much to love in recovered-memory hysteria. Lurid suspicion of daycare centers could be taken to vindicate reservations concerning women working outside the home and retaining professional assistance in child-rearing. Fantasies of Satanist conspiracies were, in part, the revenge of a threatened Christian cosmos. Sentimental rhetorics of childhood innocence bespoke a refusal of the dominion of eros. Indeed, one recent account, that of n+1 editor Richard Beck, describes the entire daycare and ritual-abuse craze as the Reaganite right’s backlash against the sexual revolution. But this is so partial as to be absurd. As Kay Hymowitz notes in a review of Beck’s book for The New York Times, feminists were drivers of the recovered-memory movement, supporting even its “conservative” manifestations: “Gloria Steinem donated to the McMartin investigation, and Ms. magazine ran a 1993 cover article, ‘BELIEVE IT! Cult Ritual Abuse Exists.’” And in its more pervasive and durable emphasis on incest, the recovered-memory movement proposed an anti-patriarchal account of the family as a structure of oppression and exploitation, and of male sexuality as malignant, the source of all psychological and social ills.
“Cultural conservatives could find much to love in recovered-memory hysteria.”
Beck wasn’t wrong, however, to document recovered memory’s conservative inflection. The memory wars of the 1980s and ’90s were not politically polarizing, because left and right could assimilate the recovered-memory movement to their separate critiques of American society. Skepticism was likewise bipartisan: Debbie Nathan, writing in The Village Voice, was at the forefront of skepticism of the McMartin allegations. Dorothy Rabinowitz wrote influentially in Harper’s in defense of Kelly Michaels, convicted in 1988 of the sexual abuse of 20 preschoolers, and in The Wall Street Journal in defense of the Amirault family, convicted in 1986 of the sexual abuse of eight children in their daycare center. (Michaels’s conviction was overturned in 1993; the convictions of Violet and Cheryl Amirault were overturned in 1995; Gerald Amirault, denied a commutation in 2002 by Massachusetts Gov. Jane Swift, was released on parole in 2004.)
The bipartisan appeal of recovered memory broadened its constituency. It allowed this rather esoteric psychiatric thesis to break through as a byword and idiom for distress, the diagnosis of first resort, for thousands of therapists and millions of patients. Recovered memory demanded credence even where its claims were incredible, as demonstrated by the evidence-optional daycare hysterias and the unfalsifiable dogmas concerning traumatic memory. As the psychiatrist Roland Summit proposed in his seminal paper, “The Child Sexual Abuse Accommodation Syndrome” (1983), a victim’s accusation of abuse was to be considered confirmation of abuse; her denial of abuse was likewise confirmation of abuse; her retraction of her accusation was no less confirmation of abuse. Recovered memory’s factual contentions were exempted from standards of facticity. In other words, it enjoyed the privileges of an ideology.
Though the 1980s established that recovered memory can be useful to the cultural right, contemporary developments show, what a consideration of its antecedents would suggest, that it is more durably and structurally congenial to the cultural left. The ideological purification of the recovered-memory project both narrows its appeal and sharpens it. The movement today is smaller, but it has a clearer direction.
In accounting for the persistence of recovered memory in the therapeutic and legal arenas, Crews points to the failure (or refusal) of the American Psychological Association and the American Psychiatric Association to enforce “scientific standards for the practice of psychotherapy.” He also cites “canny attorneys” who “coach their witnesses not to reveal” the provenance of their recovered memories and thus forestall Daubert hearings or scrutiny at trial. Another legal maneuver cuts just the other way, thanks to incentives created by mental-health or recovered-memory exceptions to statutes of limitations for sexual abuse. In jurisdictions in which the statute of limitations is tolled until an accuser becomes capable of remembering the abuse, presenting a memory as recovered allows an accuser to bring a claim that would otherwise be barred. (Skeptics of recovered memory most often contend with pseudo-memories that are artifacts of therapy; the tolling of statutes of limitations can equally incentivize the false claim that a true memory is an artifact of therapy.)
A version of this operation appears in recent litigation between Gareld Duane Rollins and Paul Pressler, a former Texas judge and a leader of the “conservative resurgence” in the Southern Baptist Convention in the 1980s. In a late-developing extension of #MeToo, the SBC has been roiled by claims of ministerial sexual abuse and coverups. (The alleged victims are typically female, though all of Pressler’s several accusers are male.) Rollins’s civil suit against Pressler was dismissed in 2018 due to Texas’s five-year statute of limitations on sexual-abuse claims; it was revived this April under the state’s “unsound-mind” exception. Due to trauma and manipulation by Pressler, we are told, Rollins endured a 35-year “period of incapacity” until 2015, at which time, with the help of therapists, he recovered his repressed memories of abuse dating to 1980. Since Rollins reported the abuse promptly upon his recovery of his faculties, argue his lawyers, he should be understood to have complied with the statute of limitations. On April 1, the Texas Supreme Court agreed and returned the case to district court. Setting aside the truth or falsity of this or any other allegation against Pressler, Rollins’s case demonstrates the usefulness of recovered memory in rendering old claims justiciable.
In addition to retaining or gaining support among America’s therapists and trial lawyers, recovered memory has recently gained new political salience. The first clear sign was The Keepers, a Netflix series that succeeded in making the memory wars a topic of conversation on the internet in the summer of 2017, on terms favorable to recovered memory.
Proffered by the streaming service as part of the wave of “prestige” true-crime documentaries, The Keepers is in many ways a millennial text. But it also recalls the sensational presentation of ritual-abuse cases by television news magazines during the early 1980s. The matter is familiar: Alumnae of a Catholic girls’ high school in 1960s Baltimore claim to have been violated in extravagant ways by authority figures (several priests and religious brothers, police officers, a gynecologist). Religious paraphernalia are props during episodes of abuse. The tale gets wackier with the claim of the documentary’s star, the most prolific accuser, Jean Hargadon Wehner, to have been shown the corpse of a murdered nun who taught at the school—a warning of what happened to tattletales. Wehner recovered the memory of Sister Cathy’s corpse during a meditation session, the source of all her memories of abuse at the school. The documentary’s efforts to pin the murder of Sister Cathy on a deceased priest named Father Maskell (or on someone, anyone, who might be even tenuously connected with him) are torturous and bizarre. More pertinent is the documentary’s account of “the Science.”
The documentary proposes that Wehner and her classmates were victims of bad timing, as the mid-1990s, when they began to lodge their complaints, were uniquely hostile to recovered-memory claims. The arguments of recovered-memory skeptics don’t receive a hearing. McHugh, whose testimony helped prevent a civil suit connected with the charges from proceeding to trial in 1994, is presented sinisterly through archival footage as “Mr. Catholic Psychiatrist,” a tool of the archdiocese. Over screenshots of a research paper and a Guardian article, Yale psychiatrist L. M. Lothstein proclaims: “We now know so much more about memory. It’s scientifically accepted that memories can be compartmentalized and not known to the conscious ego.” The late A. W. Richard Sipe, junior colleague of McHugh on the faculty of psychiatry at Johns Hopkins, provides the more revealing quote: “I believed [Wehner]. There are things that have the ring of truth, even if they’re hard to believe. And she was believable to me.” With Sipe’s three variants of “believe” in as many sentences, The Keepers concedes the true grounds of its credence. The “ring of truth” evidently does not entail non-contradiction, traditionally an attribute of truthful statements. But the theory of recovered memory entails an ambitious account of self and society; it will not pass up an occasion to call for vindication of the repressed and oppressed.
The documentary’s treatment of “the Science” proved persuasive to millennial journalists who don’t remember the memory wars and who sense their ideological interest in this matter. Kaleigh Rogers, writing for Vice, reported on the results of her Google search: “Since [the mid-1990s], the science has become more clear. Some experts now say false memory syndrome, the condition where someone remembers something that never happened, isn’t really a thing, or at least, it’s very rare.” Notable are Rogers’s glibness as she pretends to mastery of a contested body of science, and her failure to distinguish between “some experts” and a scientific consensus. Mark Pendergrast, a veteran of the memory wars, wrote in response: “I fear that she is representative of a new generation who will be vulnerable to these dangerous theories.”
”We are again in a historical moment like the early 1980s.“
Within months of its release, The Keepers had been appropriated as a #MeToo document. In The Atlantic, Sophie Gilbert proposed that the documentary had “anticipated the Weinstein Moment”: Among other things, it “revealed how single reports of abuse and assault can have a domino effect, encouraging countless more women who’ve lived silently with their own experiences to speak out.” The critical, commercial, and cultural success of The Keepers indicates that we are again in a historical moment like the early 1980s, when popular media are eager to credit recovered-memory claims, indeed to obey and propagate the affirmers’ demand that they be accorded special deference. In a striking reversal of the skeptics’ achievement in the 1990s, the “witch-hunt narrative” seems to have been succeeded by the witch hunt proper.
In Memory Warp: How the Myth of Repressed Memory Arose and Refuses To Die (2017), Pendergrast warns that though “the high-profile daycare hysteria cases … are no longer making headlines, unpublicized cases of false allegations of sexual abuse ruin lives every day.” He adduces a small sampling of hundreds of pleas submitted recently to the National Center for Reason and Justice, a nonprofit that facilitates financial and legal assistance for those who may be unjustly accused or wrongfully convicted. But since Pendergrast’s book went to press, two high-profile sex-abuse cases have emerged: the 2020 trial of Harvey Weinstein and the 2018 “trial” of Brett Kavanaugh. These iconic cases of the #MeToo movement demonstrate the ideological complexion of the new campaign on behalf of old dogmas about traumatic memory.
Weinstein’s trial on five counts of criminal sexual acts gave rise to a rhetoric about survivors’ memories that insists on their accuracy and indelibility, even (or especially) once they have been “enhanced” by therapy. One supporting witness, Tarale Wulff, had presented memories of victimization by Weinstein that were so confused as to be useless to the prosecution. The problem was rectified by Wulff’s 50-odd visits to a psychologist (disparaged by the defense as a “memory doctor”). Might Wulff’s memories have been manipulated during these sessions toward the outcome desired by the prosecution? Loftus was retained as an expert witness. News that the defense had lined up a veteran of the memory wars to contest the operations of traumatic memory elicited pushback from the #MeToo movement. An essay by two trauma psychologists, published by The Conversation, condemned the defense gambit for its dated science (“The notion of false memories has its roots in the 1990s”) and its cruelty (“These assertions … invalidate survivors and keep them from receiving the support they deserve”). Elle published a review of “rape myths,” which reproached Loftus for her claim that “memories fade.” The Time’s Up Foundation, the leading institutional home of #MeToo, warned of “The Danger Behind the ‘False-Memory’ Myth” and insisted on the indelibility of traumatic memory: “Most scientific research shows traumatic events of all kinds are often cemented in a person’s memory. And current research shows that memories of sexual assault are even more vivid than memories of other sorts of traumas.”
Time’s Up rightly calculates that the indelibility of traumatic memory is crucial to the recovered-memory thesis. For unlike continuous memories, which are sustained and refurbished (and modified, to a greater or lesser degree) by recurrence, traumatic memories need to remain accurate and reliable even as they lie untouched for years or decades. Recovered memory accordingly holds that traumatic memories get “locked in,” as Kavanaugh accuser Christine Blasey Ford put it in her Senate hearing, so that they are not gone even when they are forgotten. Blasey Ford, a professor of psychology, didn’t claim to have recovered her memory of Kavanaugh’s alleged assault—but it is a distinct possibility, given that the memory appears to have emerged in a therapeutic context. Blasey Ford once co-authored a paper commending the use of recovered memory therapy, and she explained to the Senate the indelibility of traumatic memory in biochemical terms: “Just the level of norepinephrine and epinephrin in the brain that sort of, as you know, encodes that neurotransmitter, encodes memories into the hippocampus. And so the trauma-related experience then is kind of locked there, whereas other details kind of drift.” Blasey Ford’s attempt to invoke the authority of science led her to utter the unforgettable line: “Indelible in the hippocampus is the laughter.” Around the internet, Blasey Ford’s vintage-1990 psychobabble was hyped as “the science behind” her story, establishing as gospel truth what otherwise would have been open to doubt.
If The Keepers suggested that we had entered a cultural moment not unlike the early 1980s, confirmation was provided by the Kavanaugh and Weinstein cases, in which the guilt and innocence of living parties was in question. In both cases, we observe the mobilization of woke rhetorics of belief: On the one hand, science vindicates credence in claims of traumatic memory; on the other hand, belief in such claims is simply a moral imperative.
The dubious presentation of Blasey Ford as an ingenue evokes one irony of the recovered-memory movement and of #MeToo: While purporting to empower women, these movements portray them as eternal victims, lacking agency, ignorant even of the content of their minds. They infantilize those they claim to champion. The slogan of the 1980s was “We believe the children,” but that category was best understood as comprising women and children, or women-as-children and children. Today, children are scarcely more prominent as victims than men are. #BelieveWomen circumscribes the concerns of the affirmers of recovered memory no less than the concerns of #MeToo at large. This narrowing of concern coincides with the absence of the cultural conservative side of the memory wars.
“While purporting to empower women, these movements portray them as eternal victims”
Judith Herman’s 1994 lecture to the American Psychiatry Association upon receiving its Guttmacher Award for forensic achievements amounts to a precocious articulation of woke doctrine on sex-abuse claims. “The therapist’s role,” says Herman, “is not to act as a detective, jury, or judge, not to extract confessions or impose interpretations on the patient’s experience, but rather to bear witness as the patient discovers her own truth.” Is the patient’s “own truth” distinct from what the world would recognize as truth? The therapist is not to ask. “When after careful reflection our patients make the decision to speak publicly and seek justice, we will be called upon to stand with them. … I hope we will accept the honor of bearing witness and stand with them.” The therapist, being neither detective, nor jury, nor judge, will bracket facts as she supports her patient’s search for “justice.”
The purification of the recovered-memory coalition therefore involves not just the defection of cultural conservatives, but a fracture, increasingly evident in various arenas since the agitations of 2020, between liberals and the woke. It polarizes those who prize truth, and the procedural norms established for its determination, from those who take their justice straight; those who seek evidence from those who self-generate it; those who would require corroboration of a recovered memory from those who accord such memories more than ordinary probative value.
The first memory wars began with aggression on the part of the affirmers; the skeptics took some years to rouse themselves. In this new round of hostilities, there is so far no organized resistance. The skeptics, after all, have disarmed. The FMSF is now nothing more than a Facebook page. Its disbanding was celebrated in 2021 by a long essay in The Cut, which heaped scorn on recovered-memory skeptics and valorized their longtime critics. Crews lauds the continued efforts of Loftus, McNally, and Pendergrast but wonders “how many members of the public have even heard of them?” in comparison with viral artifacts such as The Keepers.
In retrospect, it seems that though the skeptics won on three fronts in the 1990s—in the battle of the experts, in the criminal and civil courts, and in the media—they somehow still lost the memory wars. Their opponents enjoy two long-term advantages: They have retained the footsoldiers (the psychologists and social workers); and they have the better story. The recovered-memory myth partakes of what Rieff called “the triumph of the therapeutic.” It proposes that inside each of us is something esoteric, a truth that requires expression and affirmation if we are to become healed and whole. You cannot fact-check a myth, contain it with procedural norms, or chasten it with the scorn of elites; only another myth will do. At a time when many on the right and left propose to counter wokeness on sex or race with facts, procedure, or polemical élan, the return of recovered memory should serve as a warning.