Skeptical Inquirer
2002, 26, #3, pp 24-32 (Part 1)

Elizabeth F. Loftus

Who Abused Jane Doe?

The Hazards of the Single Case History: Part I.

Elizabeth F. Loftus & Melvin J. GuyerCover


Case histories make contributions to science and practice, but they can also be highly misleading. We illustrate with our re-examination of the case of Jane Doe; she was videotaped twice, once when she was six years old and then eleven years later when she was seventeen. During the first interview she reported sexual abuse by her mother. During the second interview she apparently forgot and then remembered the sexual abuse. Jane's case has been hailed by some as the new proof of recovery of repressed or dissociated traumatic memories, and even as proof of the reliability of recovered memories of repeated abuse. Numerous pieces of "supporting evidence" were given in the original article for believing that the abuse occurred. Upon closer scrutiny, however, there are reasons to doubt not only the "supporting evidence," but also that the sexual abuse ever happened in the first place. Our analysis raises several general questions about the use of case histories in science, medicine, and mental health. There is a cautionary tale not only for those professionals who advance the case history, but also for those who base their theories on it or would readily accept it as proof.
-The Authors


Case histories have a long and cherished tradition in science. They are compelling anecdotes, often powerful enough to generate entire theories of behavior. Freud built the edifice of psychoanalytic theory on the very few cases he saw in therapy. Bruno Bettelheim used a few cases of autistic children to conclude that autism is caused by "refrigerator" mothers (Pollak 1997). Psychiatrist Cornelia Wilbur's account of her patient, "Sybil," captivated millions of people who believed the story of Sybil's "multiple personalities" (Schreiber 1973). The case of Genie, the girl who spent the first thirteen years of her life locked in a bedroom alone, strapped to a potty chair, with minimal stimulation apart from being continually beaten, was thought to tell us a great deal about language acquisition (Curtiss 1977). John Money told the world of a boy who lost his penis at the age of seven months, and who then received plastic surgery at twenty-one months to reassign him as a girl. Money followed this girl until the age of nine; although she had many "tomboyish" behaviors, she also had a female gender identity. Money concluded from this case study and from his research with more than 100 other 'intersex' children that sexual identity is more strongly influenced by socialization than by biology.

Some case studies offer a window into human nature and physiology that would otherwise be shut. Oliver Sacks's stories of his patients' rare medical conditions reveal not only the mysteries of the brain but also those of personality (Sacks 1990). Case studies have identified some of the complex specialties of cells in the visual system: For example, one man with localized brain damage was able to recognize a face made up entirely of vegetables, but he could not recognize the component vegetables themselves (Moscovitch, Winocur, and Behrmann 1997). The sad case of the man known only as H.M., much of whose hippocampus and adjacent cortex were surgically removed in 1953, taught his investigators a great deal about the physiology of memory, for H.M. could not form new memories of events that happened to him after his operation (Ogden and Corkin, 1991). Similarly, case studies in clinical psychology can refute misguided generalizations, such as that mentally retarded people lack the cognitive ability to develop obsessive-compulsive disorder, or that taijin-kyofu-sho (fear of other people, abbreviated TKS) is a culture-bound disorder confined to Japan (McNally and Calamari 1989; McNally, Cassiday, and Calamari 1990). Case studies like these can provide compelling refutations to assumptions about "universal" aspects of human behavior.

But case studies, by definition, are bounded by the perceptions and interpretations of the storyteller. If they are well told-and Freud, Bettelheim, Wilbur, and Money could tell a story well-readers often find them far more persuasive and compelling than the stodgy numbers and cautions of science. Why would anyone question Cornelia Wilbur's account of Sybil? It was years before independent investigators learned that Wilbur's publisher thought that making Sybil a multiple personality would be more interesting-and sell more books-than telling the story of her real mental disorder, which was probably some form of hysteria (Borch-Jacobsen 1997). How many readers would ask whether the case of the boy raised as a girl was actually well adjusted, or whether the case was typical or anomalous of the many children who have had sex reassignment for various medical reasons? Subsequent investigation revealed that the particular boy, David Reimer, never adjusted well and reverted to life as a male (Colapinto 2000). But neither version of his case gives the full story because Reimer was not necessarily representative. Other case histories involving sex reassignment after ablatio penis (e.g., Bradley et al. 1998) reveal more successful adaptation. So, is it socialization or biology?

Who, at the time, dared criticize the famous Bruno Bettelheim or ask him pesky questions, such as where his control groups were (Pollak 1997)? When researchers finally did ask, they learned that parents of autistic children were no different psychologically from parents of healthy children (Markin 1997). As for Genie, there would come to pass a snarl of contradictions in reports about her, and serious questions raised about the competence of many of the scholars who wrote about her (Rymer 1993). Why did it take decades before critics were willing to expose Freud's biases in his case stories-the information he left out, the distortions of what his patients really said, his failure to consider other explanations of their symptoms and problems? (Cioffi 1998; Crews 1998; Powell and Boer 1995; Sulloway 1992; Webster 1995).

Case studies therefore illuminate, but can also obscure, the truth. In many cases, they are inherently limited by what their reporter sees, and what their reporter leaves out. This is especially true if the writer is untrained in the scientific method, and thus unaware of the confirmation bias, the importance of considering competing explanations before making a diagnosis, and so forth. To the scientist, therefore, most case studies are useful largely to generate hypotheses to be tested, not as answers to questions. When they are offered as answers, readers should be wary. What follows is a case study of a case study-a cautionary tale.


The Memory Wars

For more than a decade, psychological researchers and clinicians have been at war over the nature of memory. Many clinicians believe that traumatic experiences, particularly of repeated sexual brutalization, are so upsetting that they are likely to be "repressed," and can be recovered, accurately, years later-through therapy, hypnosis, dream analysis, and so forth. The extent of banishment from consciousness assumed in some definitions of repression was virtually total, as evidenced by the use of terms such as "massive repression" (Herman and Schatzow 1987, 12) or "fiercely repressed" (Courtois 1992, 23) or "total repression" (Briere 1992). (Later the term repression went out of fashion, and some clinicians began claiming that traumatic experiences caused dissociation, a split in consciousness, but they still mean that the trauma is completely banished from conscious awareness.)

Many academic researchers who study memory (and quite a few clinicians) have been skeptical about these notions of massive repression/dissociation. They have demonstrated repeatedly in laboratory experiments that these suggestible methods increase memory "confabulations" and errors, for example by causing people to confuse what they imagine with what actually happened. They see a lack of credible scientific support for the notion that massive repression/dissociation of repeated brutalization routinely, if ever, occurs. On the contrary, people who have survived concentration camps, systematic torture by despotic political regimes, and repeated rapes-from the victims of Serbian "ethnic cleansing" to the Korean "comfort women" of World War II-do not forget. They remember, painfully, to this day. Therefore the burden of proof has been on therapists to demonstrate the existence of this kind of repression/dissociation and confirm their belief that such traumatic memories can eventually be reliably recovered.

In 1997, psychiatrist David Corwin and his collaborator Erna Olafson published a case study that they believed provided such proof (Corwin and Olafson 1997). They told the story of a young woman they called Jane Doe, whom Corwin had first interviewed in 1984, when Jane was six years old. At the time, her biological and divorced parents were going through a tumultuous, protracted, and vicious custody dispute, and Jane was living with her mother. Jane's father and stepmother claimed that Jane's mother was sexually and physically abusing the child, and Corwin was brought in to evaluate these allegations.

From the article itself, we learn that Corwin interviewed Jane three times as a child, videotaping the interviews. In her final Corwin interview as a child, Jane told Corwin that her mother "rubs her finger up my vagina" in the bathtub, that it happened "more than twenty times . . . probably ninety-nine times." Jane also told Corwin that her mother had physically harmed her by burning her feet (which Corwin presumed was on a stove).

Corwin concluded that Jane's mother was molesting her daughter. In addition to the child's statements, he was persuaded of the abuse because Jane seemed to him to be more relaxed with her father than with her mother. The father seemed a more reliable informant to Corwin. This was so because when the mother alleged that the father had committed tax fraud, the father proved to Corwin's satisfaction that the charge was false. However, the mother, Corwin reported, had been "convicted and jailed for fraud." Corwin thought the mother unstable, because, with three previous marriages, he wrote, the mother "had a more extensive history of marital instability than the father, who had had a long-term marriage prior to marrying Jane's mother." And, he said, Jane was consistent, in the three forensic interviews, regarding the identity of her abuser and the nature of the abuse. Her account included persuasive sensory details of what the abuse felt like; and Jane reported that her mother threatened her not to talk.

Corwin had also been persuaded that Jane had been sexually abused because of the report of a social worker who saw Jane early in 1984, after Jane allegedly told her stepmother that her mother had sexually molested her. The social worker said that Jane reported that her mother "puts her finger up my vagina in the bathtub. I don't like that. She says she can do anything she wants to me. She puts cream on my vagina. It hurts." Jane complained about being fed "cracker soup," and about nightmares. The social worker found Jane's exaggerated startle response and other symptoms to be consistent with post-traumatic stress disorder.

After Corwin's consultation and conclusion, the court ruled in the father's favor, and Jane's father and stepmother assumed custody of six-year-old Jane. The mother even lost rights of visitation.

Eleven years went by, during which Corwin continued to discuss Jane's case at conferences on memory and child abuse. In 1995, wondering what, if anything, Jane herself remembered about her experiences, he contacted Jane, now age seventeen, and she agreed to be reinterviewed on videotape. Would she have repressed the memories of her mother's abuse?

According to Corwin, she had. When asked about the past, Jane recalled: "I told the court that my mom abused me, that she burned my feet on a stove, I don't, that's really the most serious accusation against her that I remember." When Corwin asked Jane whether she remembered anything about possible sexual abuse, she said, "No. I mean, I remember that was part of the accusation, but I don't remember anything-wait a minute, yeah, I do."


Corwin: What do you remember?

Jane: Oh my gosh, that's really really weird. I accused her of taking pictures [starts to cry] of me and my brother and selling them and I accused her of-when she was bathing me or whatever, hurting me, and that's-


Jane went on to recount the sexual abuse:


Jane: We were in the bathtub, and I don't have any memory, except for . . . I felt that pain. And then I remember, you know. And then it's like I took a picture, like a few seconds long, a picture of the pain, and what was inflicting the pain and then-you know, that's all the memory consists of.


Corwin regards Jane's response of remembering the pain as a "somatosensory fragment" of the sexual abuse she endured. He then showed Jane the videotapes of his interviews with her when she was six, all 2.5 hours worth. After watching the tapes, Jane said, "The little girl that I see in those videotapes I don't see as [having] made up those things, and it doesn't make sense to me that knowing the truth I would out-and-out lie like that. I have to believe that to some extent my mom did hurt me. . . ."

And so, watching the videotapes, Jane Doe wept, and came to remember how her mother had sexually abused her - memories, according to Corwin, that she had repressed for eleven years, a clear example of "traumatic amnesia." Although he noted some inconsistencies in Jane's version of events at age six and age seventeen, he said, "this sudden memory discovery appears to be accurate when compared to Jane's descriptions at age six of her mother's vaginal penetration of her."

For Corwin, this case supports the clinical assumption that traumatic memories and ordinary memories are encoded differently: "The tears and evident strong feeling this memory discovery caused Jane were not similar, say, to suddenly remembering where one has put the car keys."


Reactions to the Case

Corwin, a member of the editorial board of the journal Child Maltreatment, then invited several researchers and clinicians to comment on Jane's case for an article he was preparing to publish in the journal. Some of the commentators had seen the actual videotapes of Jane at six, talking about what her mother had apparently done to her, and also at seventeen, "recovering" this memory, at conferences where Corwin told his story. Others responded to Corwin's written account, which included excerpts from the videotape transcripts of Jane at both ages.

Most of the professionals who read about this case were persuaded that it was a full and accurate account of the story. Virtually all who saw the videotapes were deeply affected by them. Paul Ekman (1997), an eminent psychologist and expert in the field of emotion research-indeed, he is a leading expert in detecting deception from facial expressions of emotion-believed Jane's early reports of abuse: "The usually spontaneous, very rapid replies which burst forth from the six-year-old Jane," he wrote, "allow us to have confidence in the truthfulness of Jane's statements in the first interview." Ekman was also impressed by Jane's emotional expression: "Jane's emotions are genuine and expressed poignantly. Those who see the videotape are moved emotionally. I have yet to see anyone who does not have a tear in his or her eye when Jane first remembers part of what happened to her and begins to cry" (115). Ekman said he found this case to be "of extraordinary importance" (116) and urged the pursuit of other similar cases, following up children who were abused and who are now adolescents and adults.

Frank Putnam (1997), a psychiatrist, was impressed that Corwin's awareness of the risks of leading questions "permits us to accept Jane Doe's reports as truthful rather than suggested or coerced" (117). He found Jane to be "genuine and believable." Like Corwin, Putnam was impressed with the somatic components of Jane's memory of the pain, which he said is "typical of recalled traumatic moments" (118). He emphasized the "high degree of similarity" between what Jane Doe said at age six and her delayed recall at age seventeen, and felt the case "provides concrete evidence that delayed recall of traumatic childhood events does occur" (120).

Jonathan Schooler (1997), an experimental psychologist, agreed that this case supported Corwin's conclusion that "Jane's mother did in fact engage in inappropriate sexual behavior that was both invasive and painful" (126). Schooler was persuaded by the "strikingly consistent characterization of Jane's allegations across interviews with two psychological evaluators, one police investigator, her therapist, and in the three interviews with Corwin" (127). Schooler was also influenced by the "persuasive manner" in which Jane described the abuse, her "earnestness" when she described her mother's threats and abusive behavior, and "the sincerity with which she gave the Brownie Oath that she was telling the truth" (127). Schooler expressed his hope that skeptics would be persuaded by this case that individuals really can have repressed memories of "authentic incidents of abuse."

Stephen Lindsay (1997), an experimental psychologist who studies memory and children's testimony, said that the case of Jane Doe is "destined to be an extraordinarily important article." He applauded the article for being balanced and constructive. Lindsay did note that "the important question of whether Jane's childhood reports of the bathtub molestations were accurate" is something we are not in a position to know for sure. But he added that "The recollection of being digitally penetrated in the bathtub converges in its core content with the original allegations . . . is consistent with Jane's prior knowledge and beliefs, was remembered quickly and easily, and appears to have been clear and intense, all of which are consistent with the hypothesis that the recollection is essentially accurate" (189). Although Lindsay acknowledged that Jane might have been remembering the prior allegations rather than actual events, and reminded readers to maintain some uncertainty about the accuracy of the memory, he said he was inclined to believe that Jane's mother did "push her finger up Jane's vagina in a sexually abusive way." The foundation for his belief in the bathtub molestation was "somewhat shaky," he said, but he just got "the feeling that Jane experienced a powerful and essentially accurate recovered memory" (190).

Only one memory researcher, the cognitive psychologist Ulric Neisser, maintained strong skepticism. He observed that Jane's recovered memories-one of accusations that her mother took pornographic photos of her and her brother, and one of her mother's molesting her in the bathtub-were far from accurate. The memory of the photos was "entirely false." The second had changed dramatically. The six-year-old Jane claimed that her mother molested her while bathing her, putting her fingers into Jane's vagina and asking, 'That feel good?' many times. But the seventeen-year-old Jane remembered a quite different event-the picture now in her mind "is of a single, deep vaginal intrusion, several seconds in duration and extremely painful" (124). Neisser wrote that perhaps the single dramatic event in Jane's age-seventeen memory misrepresents a long series of "unpleasant but relatively pedestrian childhood experiences"-being bathed by her mother. Still, he later referred to them as "irritating and unpleasant bathtub episodes, clear examples of abusive behavior on her mother's part." After reminding readers that discovered memories that return can be entirely false, partly false, somewhat distorted, or also accurate, Neisser nonetheless expressed his gratitude to those who made the videotapes available.

Once in the literature, Corwin's case history was embraced by many. One group of pro-dissociation writers described it in detail, and then commented that the case was a "good example of substantial forgetting and later recovery of a corroborated childhood sexual abuse memory" (Brown, Scheflin, and Whitfield 1999, 65). Lawyers presented the case at conferences, assuming it was authentic (e.g., P. Brown, 1999). Expert witnesses began presenting the case in court as concrete proof of the validity of repressed memories (State of Rhode Island v. Quattrocchi 1998). Professors began teaching the case in their university courses (Steve Clark, personal communication 8/16/01).

Thus Corwin's case study was vivid and compelling. Leading scientists were persuaded by it; indeed, emotionally moved by it. Few considered any other possible explanations of Jane's behavior at six or at seventeen. Few were skeptical that Jane really had been abused by her mother before age six, that her retrieved memories were accurate, or that "repression" accounted for her forgetting what her mother supposedly had done to her.

But we were. In 1984, when Corwin was called in to assess this case, Jane's parents had already been battling over her custody for five years. (They separated for the first time when Jane was only 8 months old.) In those days, few experts were aware of the way children's memories can be tainted by interviewers who are on a mission to find evidence of sexual abuse. Few knew how to interview children in nonsuggestive, noncoercive ways. Many social workers and clinicians believed that children don't utter falsehoods about sexual abuse-a premise that has long been shown to be wrong. Like adults, children can tell the truth, and they can also be influenced and manipulated into saying things that are not so (Ceci and Bruck 1993). Psychological science has contributed a great deal, especially since the early 1980s, to our understanding of the malleability of memory of adults and children.

In the last two decades, the two of us have conducted research on these issues and testified in court cases, out of our concern about false allegations of abuse-allegations that are especially likely to occur in emotionally fraught custody battles. So, just as Corwin had a vested interest in persuading others that his initial judgment about Jane was correct-that the mother had indeed molested her-and that some repression-like process is indeed the mechanism that prevents children from remembering such trauma, we had a vested interest in learning if he had provided the whole truth, and nothing but the truth.

And so we set out on an odyssey to learn more about the case. Our investigation produced much valuable information that should assist scholars in making their own decisions about whether Jane was abused, and if so, by whom.


Our Search for the Full Story

Corwin disguised the case-using names like Jane Doe and John Doe, Momstown, Dadstown. But he showed the tapes at a number of professional meetings, and the tapes mention Jane's real first name and the city where some of her childhood activities took place. We searched legal databases with a handful of key words, and found an appellate court case involving Jane.

From the case we learned that Jane's father, whom we will call "Dad," had been found in contempt of court for failing to comply with visitation orders on three separate occasions. He was sentenced to fifteen days in jail for refusing to allow Jane's mother and grandmother their court-ordered visitations with Jane. This was interesting; why did Corwin mention the mother's jailing but not tell us about the father's? Corwin had made a point of the mother's jailing for "fraud" in comparing her credibility to the father's; we learned that she had been incarcerated for misdemeanor welfare fraud, during which time Dad was given temporary custody of Jane. Upon her release, Mom sought custody. The court, however, based on Dad's accusations that Mom had physically abused Jane by "burning" her feet on the stove, ordered joint custody to the parents and physical custody to the father. The custody war escalated, eventually involving allegations by Dad that Mom abused Jane not only physically, but sexually.

When Child Protection Services (CPS) in the mother's home county investigated these allegations, however, they turned up nothing, and CPS recommended that no action be taken. The father then went to another county, eighty miles away, to repeat in another court his allegations that the mother was sexually abusing Jane and had burned her feet "months and years before" (according to the published court case). This involvement of a second court, one which challenged the jurisdiction of the first court, led to the appellate case that resolved the jurisdictional dispute over which court had primary control when child abuse was alleged. One appellate judge, writing in that opinion, explicitly criticized the father for this "blatant forum shopping for the sole purpose of avoiding what he anticipated would be adverse rulings by the (Mom's county) court on the various custody and visitation motions then pending in that court." Why did Corwin not tell us that the mother's county CPS had thoroughly investigated the father's charges and recommended that no action be taken? Of course, this doesn't mean that no abuse occurred, but the information is surely relevant.

From this appellate court case we now knew Dad's first name and the first letter of his last name, but the rest of his identity was not revealed. We knew only, from Corwin's article, that he had died in November 1994. After a long and tedious search of the social security death records and newspaper obituaries, we found out who he was, and from there we uncovered the full history of the custody dispute and the abuse allegations.

Corwin informs readers of the report of the social worker, who believed Jane's claims against her mother. But he omitted a letter from a clinical psychologist (Dr. S.), written to a judge in February 1984. Dr. S., in accordance with a court order, had interviewed Dad, StepMom, Mom, and Jane. He spoke with Mom's therapist, Jane's psychologist, a CPS worker, Jane's brother, Grandma, and Mom's attorney. He read police reports, court orders, medical reports, and court transcripts. Dad told Dr. S. that Mom abuses Jane: hits her, pulls her hair, calls her names ("you shit"), and sticks her fingers up Jane's vagina and anus to clean her out, allegedly asking "does that feel good?" while doing so. Mom denied doing these things, and told Dr. S. that three CPS investigations and numerous court proceedings related to these charges had occurred, but none found her guilty of the "supposed abuse."

Dr. S. wrote in his letter to the judge that although some documents supported the premise that some type of abuse had occurred, "what has not been made clear is the source or nature of the abuse-whether these are actual physical and sexual abuses perpetrated by (Mom) or whether they exist only in the mind and fantasy of (Dad) and are communicated to (Jane) as (Mom) contends." Dr. S. noted that Jane's narration of her story was not spontaneous: "She has told her story numerous times to a number of different people and she now sounds mechanical." As for the burned feet, he said: "It was never determined if her feet and hand were indeed burned, since (Jane) has a fungus condition that causes her skin to blister and peel."

So in addition to whatever a social worker may have believed about the abuse, we would learn that a psychologist had a compelling dissenting conclusion. And, importantly, an alternative explanation existed for the allegedly "burned feet."


Mom's Life - Then and Now

With Dad's last name in hand, we wondered whether we could find Mom from information contained in the divorce file. Our assistant found Mom and contacted her at her modest home. When he explained why he was there, Mom welcomed him, sobbing her way through his interview, saying, "I never thought this day would come." The court battle she had had with Dad over Jane was a "nightmare," she said, "that never ended." The situation devastated her financially and destroyed her health. Throughout the years she expressed her grief in unpolished poetry which she shared with us.

Mom also described the consequences of Corwin's reappearance in her daughter's life. After Dad died in 1994, Mom was able to renew contact with her daughter, and had had a "very positive relationship" with her for about fourteen months. It ended, she said, when Corwin arrived on the scene. As our assistant reported: "Dr. Corwin contacted (Jane) to 'review' the old allegations that were made against Mom. . . . Mom said that after Dr. Corwin 'reviewed' the allegations with Jane, she allegedly recovered a memory of Mom bathing her. This memory made Jane believe that she in fact was molested and abused by Mom. After Jane's contact with Dr. Corwin, Mom received an angry telephone call from Jane. According to Mom, Jane screamed at her in a hostile manner, accusing Mom of molesting her. Jane cut off contact with her mother."

Mom's mother's closest friend, whom we'll call Alice, had known Mom since she was born, and also had strong views. She was familiar with the custody case, as she had attended almost all of the court proceedings and frequently went with Mom to pick up Jane for visitation. Alice described Mom as a good person and good mother. She talked of the trauma of the custody battle for Mom: "[Dad] had quite a bit of money, and he was able to pay for his attorney to continually take Mom to court." Alice was adamant that "no way did any of the allegations occur." Mom, she said, loved Jane and would never have harmed her in any way; it was Dad who coerced Jane to make up the allegations. Alice also reported that Dad treated Jane's older brother, "John," badly.

John, now in his thirties, has concurred that in no way did his mother ever abuse Jane. On the contrary, he said, it was his stepfather who was the abusive one, both to himself and to his mother. John had memories of Dad beating him with a belt that had metal circles on it, leaving imprints on his skin. John said that he was never interviewed by Corwin regarding this matter.

After reviewing this preliminary information, we contacted Mom directly. She was eager for us to visit, which we did. She lives in a town of pickup trucks and soda fountains-an "American Graffiti" sort of place. Mom told us a few things, of course from her perspective, that never appeared in any of Corwin's accounts of this case:


  • On Dad's presumably good qualities as a father: Dad had two older children other than Jane from a previous marriage, with whom he had no relationship. He "left them $l in his will," Mom said.

  • On the custody war: "I was broke in every sense of the word. I couldn't defend myself." Indeed, Dad had retained a successful lawyer whereas Mom had to rely in large part on legal aid.

  • On the allegations of the burned feet: Mom confirmed what was in Dr. S.'s report in the divorce file: Both she and Jane had a bad fungal condition, which leaves scarring that can seem like burns. Mom even showed us some remnants of this condition on one of her fingers.

  • On why she divorced Dad: He would scream at her all night long. He drank scotch in the way that most people drink water. He'd drink it straight, sometimes finishing off the whole bottle. He threw her around. Dad told her if she left him he would take Jane away from her and destroy her life.

  • On Dad's honesty: He got money by reporting supposedly stolen or lost jewelry to the insurance company.

  • On the welfare fraud for which she spent two months in jail: Because Dad paid child support so erratically, she never knew when she would be getting money from him. So Mom had filled out forms saying Jane's father was not supporting Jane. She neglected to mention a few payments that had been made, and was therefore convicted of welfare fraud.

All in all, a different picture from Corwin's portrayal of the credible, kindly dad and the thieving, abusive mom. Why did he not give us Mom's perspective-that Dad was a problem drinker, that he beat her son, that he had cheated an insurance company? As we dug into the history of this troubled marriage, we found more information that Corwin had omitted in his case study, all in public records.

When Dad and Mom first separated, Mom was awarded custody and support of $200 per month. Just nine months later, Dad asked the court to reduce his child support to $100 per month. He also asked for more specific visitation rules. Because he was in arrears on his child support, she was refusing visitation, and Dad asked that Mom be found in contempt of court for denying visitation. She responded by asking for supervised visits between Dad and Jane, claiming that he was "emotionally unstable and he drinks and uses drugs and alcohol to excess."

The court reduced child support, designed more specific visitation for Dad, and found Mom in contempt for not permitting the ordered visitations. But the couple continued to quarrel, in and out of court, over the next years.

One day, when Dad picked up Jane for a visit (she was not yet four years old), he noticed a problem with her feet and took her to a hospital in his area. The doctor there reportedly found what could be construed as "almost completely healed second degree burns on the plantar feet and palmar left hand." Dad then took Jane to another hospital, and that report too indicated that "old burns of both feet and left hand were found."

Shortly thereafter, the father's attorney put in requests for records from hospitals, the sheriff's department, child protection agencies, and other institutions relating to "possible child abuse incidents relative to" Jane. By this time, Mom's welfare difficulties were underway. While she was briefly in jail, Dad got custody, and he was explicitly ordered not to drink while with his daughter. The same order gave Mom's mother, Grandma, visitation rights.

When Mom was released from jail, she filed for custody of Jane. Grandma signed the following declaration in support:


The primary concern I have is for the safety and well being, both physical and mental, of my granddaughter Jane. Toward this end I wish to advise the Court that Dad is a character of extreme emotional instability. When my daughter and Dad were living together, Dad would regularly assault my grandson, John, who is now age eleven (11). On one occasion in 1977, my grandson was beaten so severely he was unable to remove himself from his bed for an entire day. His entire face was swollen to a pulp and he was unable to move. Although that particular occasion was the most severe, it was not an isolated incident. It is my belief that Dad has a problem associated with alcohol which may have resulted in such violent activity.


Mom did get custody back. Jane was now almost five years old, but Dad's efforts to gain custody escalated. A judge found that both parents were concerned about their child, but he was worried about the apparent findings by an emergency room doctor that there were burns on Jane's palm and fingers of the left hand. Thus, "out of an abundance of caution," the Court decided to award joint custody, with physical custody with Dad, and "reasonable rights of visitation to (Mom) as the parties can agree." The Court ended its order by quoting the words of a clinical psychologist that it is "unfortunate that the child has to bear the effects of this contest."

Even so, the contest was not over. Within a year, Dad was claiming that Jane had told him that Mom was abusing her, and Mom was complaining about visitation problems caused by Dad. The litigation dragged on and on, and in mid 1984, when Jane was five, Corwin entered the case and began his forensic interviews. He sided with the father's version of events, opining that Jane had been physically and sexually abused by Mom. Based on Corwin's report, a child protection staff worker in [Dadstown] recommended that Jane have no contact with her mother. Given his belief, it remains a mystery why no child abuse charges were filed against Mom.

And there matters ended-almost. Dad had succeeded in removing Mom from Jane's life, and she, too exhausted after a five-year battle, gave up her efforts to pursue her rights for visitation. When Jane was nine years old, her father and stepmother divorced and her father had bypass surgery. When Jane was about fifteen, Dad fell seriously ill and entered a convalescent hospital. Jane went into foster care; Dad died a year later.


Jane's Life After Mom Was Gone

Next we interviewed Jane's foster mother, who talked for nearly four hours, of course from her perspective. What follows are her recollections as revealed to us. When Jane came to stay with her, FosterMom said, Jane was extremely distressed. Her father had had a heart attack and could not care for her. Her stepmother, long divorced from her father, was out of the picture.

At FosterMom's urging, Jane tried to put the "puzzle pieces" of her past together. They talked about her memory of the "burned feet," and at one point even checked out the mom's "electric stove" whose coils had allegedly caused the burns; they found it was a gas stove-there were no coils to leave an "imprint." They wondered whether she had perhaps burned her feet when she walked on hot cement in the summer. But at other times, Jane would come up with "visions." She saw herself standing on the stove, and she would cry.

Eventually, FosterMom contacted Mom, and invited her to visit. The first meeting, said FosterMom, was "really beautiful." The night after her mother left, Jane said, "I knew she was my mother. It felt so familiar."

During this period of Mom's visitations, Jane began rethinking the subject of sex abuse. According to FosterMom, at first Jane hated her mother, thinking it had happened. Then she began to have doubts, wondering whether she could have made it up. Together, FosterMom and Jane explored what Jane remembered. Jane kept worrying. "What if I just said it? What if Dad put me up to it? I said it but did it really happen?" And then: "I wouldn't have said it if it didn't happen."

And then, as Jane was struggling to find out the truth and beginning to question whether the abuse had even occurred-as her father had repeatedly told her-Corwin entered the picture. He called FosterMom, saying he was doing research and wanted to interview Jane again. Jane wanted to do it to learn more, so FosterMom took her to the interview. When Corwin showed her the tape of herself at age six, Jane held her head and screamed, "Oh God! She did it! She did it. I can see it. I can see it." FosterMom said it broke her heart to watch Jane's reaction. After that, said FosterMom, she knew for sure, "beyond a shadow of a doubt," that Jane's mother had abused her. "That was," she concluded, "an ugly day."

FosterMom heard the phone call that Jane made to Mom after her interview with Corwin. It was short, cold, and angry. Jane called her by her first name (not Mom), and said something like, "I know that you molested me." Jane wrote a letter to her mother that FosterMom had a chance to read: "You did this. Why did you do this? How could you do that to your little girl?" She would not listen to her mother's protestations that Dad had made it up.

According to FosterMom, Jane changed dramatically after the interview with Corwin. She went into herself. She became depressed. She started behaving in self-destructive ways, and soon left FosterMom's home. At our meeting, FosterMom said she hadn't spoken to Jane in ten months, ever since Jane called her, angry and belligerent. FosterMom wondered whether Jane was suffering because of having seen the tape. Had the "Corwin thing" sent her over the edge, or was she unhappy for some other reason? Was she rejecting FosterMom because of the older woman's strict rules against staying out late and misbehavior, or because she was trying to run away from her own misery? FosterMom mused: "Would she have been better off not to remember? I don't know."

There was one other person to interview: StepMom, to hear her perspective of the sexual abuse allegations and where they came from. Early in the interview, she volunteered that the way that they got Jane away from Mom was "the sexual angle." "We proved it," StepMom said. "We saw abuse on her body. We started documenting it."

We asked her about the trip she and Dad made to the hospital in June of 1982 to have Jane's feet checked. StepMom said Mom burned Jane's feet because Jane wasn't staying in her room. Mom had "johns" over and was getting fed up with Jane. "Jane told us what happened, and we saw the burns," StepMom said. "It was with an electric coil. You could see these on the bottom of her feet." When asked why they went to second hospital with Jane that same day, she said, "We stopped at two of them. We stopped at 'here' first, then 'there' to get documentation. We wanted to document as much as we could. We were building a case against this woman. We were going for broke."

StepMom's animosity towards Mom was apparent throughout the interview. She accused Mom of being a prostitute, of locking Jane in her bedroom, of leaving her abandoned, and of binding the child and placing her feet on the stove. She called Mom a "leech," a woman who always had her hand out. "She has a black soul," she said.

StepMom accused Mom of taking soft-porn photos of John and of Jane, and peddling them. We asked how she found this out. "The police found it out," she replied, "and also Jane told us she was posing with John and that her mother was taking pictures. That's why I say she's a blackened soul." We asked whether the police ever found the photos. "I'm not sure," she said.

She later added that Jane had talked with her about the sexual abuse from ages four to nine. Although Corwin would claim that Jane had "repressed" the memory, both FosterMom and StepMom reported to us that Jane did talk about those past experiences frequently. StepMom said:


She always remembered it. But there was just the times that she wanted not to talk about it because of what it brought back. We talked because we were very close. Her mom would lie to Jane and you know, she would be in the bathtub bathing Jane, but she would tell Jane the reason why she put her fingers up her vagina was to get her clean. . . . But the way she did it was hurtful to-very rough. And not just up, but back and forth, back and forth. And I said to Dad, I said, "what she's doing basically is getting this child ready to use her later on for sex."


Later in the interview, StepMom said proudly, "I helped get Jane for Dad because we were married. I was a much younger woman. I don't have any bitterness toward Mom, I'm just saying, thank God Jane got out. And everything that Dad and I was, did together, was not in vain. . . . All that money we put in and all the time that we sacrificed, and, [it] was worth it. I'd do it all over again. All over again."

Of course, a current wife's anger and antipathy toward her husband's former wife, especially where issues of money and custody are involved, are quite understandable, and in some cases justifiable. How, then, should a scientifically minded investigator assess her testimony in contrast to Mom's account of events? Which is more credible? In science as in a court of law, both women would be cross-examined, and supporting or disconfirming evidence would be brought to bear. Corwin, of course, accepted StepMom's version of events relatively uncritically. But here is some evidence that might lead one to question her motives and account of events. Other evidence bears on StepMom's marital history or legal troubles-the type of evidence Corwin used to compare relative credibility, however dubious such comparisons on this basis might be:


  • Dad and StepMom married on 12/30/83, the very same month that Jane would make her first "reports" of sexual abuse about Mom; the couple separated three years and ten months later. Jane was only nine. Dad accused StepMom of appropriating valuable items from the house while he was hospitalized for bypass surgery.

  • StepMom subsequently married once again. Court documents reveal a 1991 "Order to Show Cause and Temporary Restraining Order" filed against StepMom by her new husband. He declared that StepMom had fraudulently claimed that he had physically abused her.

  • StepMom had further troubles in the mid-1990s with a misdemeanor arrest for vandalism; the charges were brought by a woman, and the case appears to have been dismissed.

In sum, we believe that there are ample reasons to doubt whether Jane Doe was physically or sexually abused by her mother, and to doubt much of the "supporting evidence" used to support the abuse hypothesis. Contrary to Corwin's claims, Jane's reports about her experience at the time were not particularly consistent. The argument that Dad had superior credibility over Mom in terms of marital stability, criminal records, and other behavior did not hold up. At least one expert, Dr. S., who appears to have done the most thorough investigation, was unconvinced that abuse had occurred. Finally, there was ample evidence that Jane talked about the abuse allegations on innumerable occasions with several people between the two sessions during which she was videotaped, undermining claims of massive repression or dissociation.

Part II (Skeptical Inquirer magazine : July/August 2002)

Many questions remain unanswered. Did Jane repress and recover an authentic memory of sexual abuse, or did she always remember the charges that cost her mother custody of her? Were those allegations accurate, or is there an alternative that might explain why Jane reported sexual abuse as a child and later came to believe it really happened? What is the truth about Jane's allegedly "burned" feet? Why were John Doe's abuse accusations against Dad never pursued?

A memory is, of course, not proof of the event it purports to recall. We all "remember" things that never actually happened, as ample scientific evidence has demonstrated (Loftus 1997). To take Jane's memory as evidence of an alleged prior event is to beg the question of whether it is a recovered memory. Instead, we must begin with an inquiry into what was regarded as corroboration of the claim of recollection. Thus we are led back to Corwin's original clinical evaluation.

There was no smoking gun in this case-no first-hand eyewitness accounts from impartial parties, no unambiguous physical evidence of sexual abuse or even of old burns. Corwin rests his corroboration of Jane's memory upon his clinical opinion that the alleged abuse occurred. The claim of corroboration naturally takes us to questions about the nature of clinical child abuse evaluations and their validity and reliability in general, and in this case in particular. Child sexual abuse is not a diagnosis. Instead such cases typically involve an effort to postdict-to say, on the basis of record review, contemporaneous observations, and credibility judgments whether some event did or did not occur in the past-an enterprise typically outside the scope of mental health expertise.

Can clinicians postdict with accuracy whether child sexual abuse occurred? Based upon a substantial body of scientific research, much of it done after Jane's 1984 evaluation, we have learned many sobering things about the limitations of clinical expertise in the postdiction of child sexual abuse.


  1. We know that clinical judgments of alleged sexual abuse may be unreliable (Horner, Guyer, and Kalter 1993a, b). Even experienced evaluators of child claims disagree markedly.

  2. We know that clinical judgments concerning the credibility of children's statements are not reliable (Ceci and Huffman 1997, Ceci, Loftus, Leichtman, and Bruck 1994), nor are clinical judgments concerning the credibility of adults particularly reliable (Ekman and O'Sullivan 1991).

  3. We know that there are few, if any, specific behavioral indicators of child sexual abuse (Kendall-Tackett et al. 1993), and to rely upon any one or two behavioral indicators will result in many false positives.

  4. We know that false allegations of child sexual abuse find fertile ground in highly contested child custody/visitation cases and that these are the most suspect cases in which allegations of abuse arise (Benedict and Schetky 1985). We know that children in such circumstances are often subject to so much parental influence that they sometimes lose the capacity to accurately report their own experiences.

  5. We know that children, especially young ones, can be made to recall events that have not occurred, especially if they are questioned about them in suggestive and leading ways.

  6. We know that interviewers and evaluators who have an expectation bias can influence the recollections and reports of their subjects to be congruent with their bias.

  7. Finally, we know that multiple interviews and repeated and prolonged evaluations erode the capacity of people to obtain trustworthy data from child witnesses. Indeed, the study of the malleability of children's memory constitutes an important area of memory research, and much of it has developed only in the last ten years (Ceci and Bruck 1995).

What does all this mean for Jane Doe's case? The claim of recovered memory here is founded upon a type of corroboration that in general terms is highly unreliable and invalid, though it was standard throughout the 1980s and 1990s. It is doubtful, for example, whether the clinical evaluation method of assessing abuse allegations would pass the "junk science" test set out by the United States Supreme Court in Daubert v. Merrill Dow, given the demonstrated lack of agreement among clinicians in these sorts of cases. (At the time of Corwin's 1984 evaluation of Jane, however, the American Academy of Child and Adolescent Psychiatry had not yet promulgated its guidelines for assessing allegations of child sexual abuse and would not do so for several more years.)

To the extent that Jane's memory can be regarded as an instance of a recovered, accurate memory, there must be some objective and independent corroboration of the events she purports to remember. If Corwin's evaluation is to serve as the corroboration of Jane's alleged abuse, it must lay some strong claim to the measure of reliability, validity, and objectivity upon which scientific claims are founded. We have argued that clinical evaluations of abuse allegations, in general, do not have the desired indicia of reliability necessary for corroborating scientific theories. There is nothing that we can see in Corwin's evaluation that distinguishes it from ordinary, subjective clinical assessments, or that allow him to make some special claim to objectivity and reliability.

Nonetheless, other important questions remain:

Even if there was no corroboration of sexual abuse, was there not corroboration of Jane's burned feet?

We learned from StepMom that Jane was taken to two hospitals on the same day to get as much documentation about the burned feet as possible. We learned from other sources that Jane had a fungal condition that could have been responsible for injuring her feet. We learned from FosterMom that Mom apparently did not have the type of stove that was supposed to have been used to burn Jane's feet. We could not access Jane's medical records, of course, because of confidentiality, but we did have descriptions about the burned feet provided in one of the CPS worker's reports. We then contacted Edwin Carlson, M.D., who was director of the emergency room at one of the hospitals where Jane was taken for examination of her feet. In response to the diagnosis of almost completely healed second-degree burns, Dr. Carlson told us: "A physician cannot tell the cause of sloughed skin when the area is healing. The sloughed area is caused by vesiculation and it in turn has many etiologies including thermal and chemical burns, exfoliative dermatitis secondary to a drug reaction, bacterial and fungal infections. Therefore the etiology in the diagnosis is related as past history by the patient or the patient's guardian."

He added that if there had been any suspicious circumstances, the chance of a report not being filed with Child Protective Services was near zero, especially with the above diagnosis. We also contacted an Emergency Room nurse who knew a great deal about the standard of care at one of the hospitals where Jane had been taken to have her feet examined. She told us that during 1982 (the year Jane was taken to have her feet examined), any suspected child abuse was reported immediately to CPS unless there was an investigation in progress in another county, that the CPS offices were in a building immediately adjacent to the hospital where Jane was taken, and that the staff were on call twenty-four hours a day. "We erred on the side of the child concerning the report," she told us. She implied that there must have been significant doubt that the "burns" were a result of child abuse.

If Mom did not sexually abuse Jane, why did Jane report abuse when she was six years old?

One possible answer: StepMom and Dad-"The Sexual Angle." A thorough examination of the data lead us to propose another equally plausible hypothesis about what happened, one that does not involve sexual abuse. Mom and Dad were involved in a prolonged and nasty divorce and child custody battle. Even allegations of deliberately burned feet had not succeeded in getting Mom out of the picture. StepMom seems to despise Mom to this day. Did she, with or without Dad's involvement, see a way to finally get rid of Mom once and for all? "The sexual angle" is the phrase StemMom used in her interview with us when asked about the initial reports of abuse. Did StepMom question Jane in a suggestive manner? Mom obviously bathed her daughter Jane, and perhaps she might accidentally have poked her. Perhaps it was ordinary bathing with vaginal and anal cleansing of the type done by many parents. Did StepMom misconstrue Jane's honest accounts of how her mother bathed her? Did she reinforce suspicions and reports of sexual abuse? Documentation from that period reveals that StepMom was the first person to whom Jane "reported" sexual abuse; only later did she tell this story to others. This is only one of the ways that Jane may have come to report sexual abuse if in fact none occurred, but there is contemporaneous documentation that is consistent with this hypothesis.

If abuse did not occur, why were so many people-including Jane herself-persuaded that it did on the basis of the videotaped interviews of Jane at six?

When someone recounts an event, especially if it is detailed and accompanied by emotion, it can be very persuasive (Bell and Loftus 1989). Jane herself was persuaded when she saw herself on tape, as were many knowledgeable scientists. Where would all that emotion and detail come from, many people assume, if the recounted events didn't happen? But of course the fact that a person has come to believe that something happened does not mean it actually did. The belief can be absolutely real and heartfelt without being correct. People who believe they were abducted by aliens, people who believe they were kings and princesses in past lives, people who believe they can recall being born (or being cramped in the womb) will also give detailed, emotional, and persuasive reports of their "memories," but it seems unlikely that they are right. Thus, Ekman could have been absolutely right in his assessment that Jane's "emotions" at age six were authentic-and absolutely wrong that she was having an authentic memory.

Where did the pornography accusations come from?

Numerous commentators have puzzled over the accusations of pornography. Corwin and Olafson's original article repeated Jane's accusations: "I accused her of taking pictures of me and my brother and selling them," Jane recalled at age seventeen (Corwin and Olafson 1997, 105-106). Neisser suggested that the pornography accusations were false: "Jane has clearly 'remembered'-and been very upset by-something that never took place" (Neisser 1997, 123). Based on our interviews, we think that these accusations may have originated in the mind of StepMom and were communicated to Jane. They were denied by Jane's older brother John, who was supposed to have participated. They were denied by Mom. No reports or documentation exist to substantiate them. They almost certainly would have been noted in police reports, therapists' notes, or other documents had they been mentioned.


The Ethics of Exploring Jane Doe's Case

Are our efforts to examine this case study ethical? Was it appropriate for us to track down information, reassess the evidence and claims, and come to a different conclusion than Corwin's? We consulted Thomas McCormick, a physician whose specialty is medical ethics at the University of Washington. McCormick offered a hypothetical situation in which a professional has published a case history claiming that he cured cancer with marijuana leaves and Crisco. Oncologists would naturally have many questions to ask of this case study: Did it really work? If the patient seems to be in better health after the "treatment," did he or she really have cancer in the first place? Would it be ethical for a physician to talk to the "case history" and to examine the original doctor's data?

McCormick thinks so, and so do we. The essence of science is its openness to examination by one's peers. Claims ought to be subject to peer review; facts must be available for verification or criticism; and findings ought to be reproducible. When an author puts forward a hypothesis based upon a case study that he maintains is true, one that he uses to defend his theory, others are entitled-indeed obligated-to scrutinize the methods and findings as long as this can be accomplished without undue harm. In the case of Jane Doe, we followed the trail left by Corwin, and we tracked down many documents pertinent to her case, and met a few individuals who knew her. We found a great deal of material that was damaging to his claims. What we did was reminiscent of the work of scholars who reexamined Freud's case of Dora, discovering crucial information about her that Freud neglected to tell his readers. Reanalyzing a case study does require detection skills.

Readers may wonder why we did not speak to Jane Doe herself. We thought long and hard about doing this. Although we obtained recorded permission from Jane's mother to contact her daughter, we worried that such contact might be upsetting to Jane-and she had surely been upset enough in her troubled young life. Given that Jane's own account at this point might well not shed additional light on the "case study," as her beliefs had potentially been so contaminated, we decided not to risk upsetting her.

Corwin and Olafson and some of the commentators proposed a new "research paradigm": future studies could take advantage of the existence of vast numbers of decades-old tapes of children making sexual abuse allegations. Adults like Jane who had been videotaped in childhood, reporting that they had been abused, could be recontacted to explore their memory of the childhood trauma. Adults like Jane could be shown their childhood tapes, as Jane was. Lindsay (1997) urged careful consideration of this idea, and after seeing what followed in Jane's life, we agree. We think this method is risky-indeed, potentially catastrophic.

If the abuse never happened in the first place, the adult-child may be mistakenly led to believe that it did because she does not understand that there are reasons why a child might make an abuse report even when no abuse had occurred. She may be led to act on the basis of this "new information" in ways that she would not have otherwise acted, with results devastating for her and others. In this case, for example, Jane terminated her newly reforming relationship with her mother after seeing her childhood tapes. No one counseled her that her age six statements, however dramatic, might have been the result of suggestion. Moreover, according to many sources, prior to Corwin's intervention, Jane was frequently questioning her "memories," talking about them, wondering what "really" happened. Did her 1995 contact with Corwin push her over from uncertain to certain?



Our efforts to critically evaluate this claim of the recovery of a repressed memory were met with unexpected and unsettling obstructions. Critics of our inquiry, some of whom shielded themselves in "confidential" memos and anonymous allegations of our supposed wrongdoing (memos to which we were denied access and hence opportunity to respond), were able to impede the publication of our work for more than two years. Indeed, our respective universities issued chilling warnings to us that we were to avoid the publication, in any forum, of any of this material, even that which is in the public domain and readily found by anyone with access to a modem and Google search engine. Our vindication, and concomitant recognition of our constitutionally protected speech, was wrested from the academy not by the shield of "tenure" and its intended protections of the spirited exchange of intellectual ideas, but through the costly (emotionally, professionally, and financially) retention of private counsel. We are alarmed on behalf of all members of the academic community that our universities, institutions that above all others should be championing the right to free speech and academic debate, so implacably opposed it in this instance.

Jane Doe's case continues to be offered as proof of the authenticity of repressed or dissociated memories in many venues, including court cases involving other, potentially innocent, accused individuals.

Jane terminated her newly emerging relationship with her mother after Corwin came back into her life and replayed her childhood tape. Her mother lost her once, long ago in 1984, and lost her again in 1995. At this writing they are not in contact with one another.



We are enormously grateful to Carol Tavris, so generous of her time and her talent, a veritable muse. Many other individuals, friends and colleagues, provided valuable insights and editing assistance.



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About the Authors

Elizabeth Loftus is professor of psychology and adjunct professor of law at the University of Washington. She is past president of the American Psychological Society and author of twenty books and more than 350 scientific articles. Address: Psychology Department, Guthrie Hall, University of Washington, Seattle, WA 98195-1525. E-mail:  

Melvin J. Guyer is professor of psychology, Department of Psychiatry, University of Michigan Medical School, 1500 East Medical Center Drive, Ann Arbor, MI 48109-0390. E-mail: