False Memory in Trauma and PTSD

Snap Shot

• The question: Are people who have experienced trauma, or who have post-traumatic stress disorder (PTSD), more prone to false memories, and what does that research mean for their accounts of real events?
• What the research shows: Some laboratory studies find more false recall of related words in trauma-exposed and PTSD groups, mainly with emotional or trauma-related material; others find no difference or fewer errors. Recent misinformation studies with trauma-exposed and distressed participants have generally not found greater suggestibility. People with documented trauma usually remember it, and suggestion, particularly in treatment aimed at recovering memories, is the condition the research ties most closely to false memories of trauma.
• What it does not show: The research does not show that trauma survivors are generally unreliable or that they fabricate memories of their own experiences. A person’s score on a word-list task cannot show whether a particular account is true or false.
• The law: Testimony on this research is general, educational expert testimony under Rule 702 and Houser; no expert may offer an opinion that a particular witness is or is not truthful (Brooks, Lindsey, Moran). Claims of treatment-related suggestion may raise questions of access to privileged records (Mil. R. Evid. 513; R.S. v. Thompson).
• Issues for each side: Prosecutors can show that trauma and PTSD do not by themselves make a witness unreliable, but should not present laboratory null results as proof that a particular account is accurate. Defense counsel can look at the circumstances in which an account first emerged and whether suggestive questioning or treatment came before it, but should not use the laboratory studies to suggest that trauma survivors in general misremember or invent.

Researchers have long asked whether people who have lived through trauma, especially those who develop PTSD, are more vulnerable to memory error than others. The question reaches court because complainants and witnesses in serious criminal cases have often experienced trauma, sometimes the very event at issue, and because many treatments ask patients to revisit traumatic memories. If trauma or PTSD changed vulnerability to suggestion, that would bear on how such witnesses should be interviewed and how their accounts should be evaluated.

The question is easily misused in both directions. A laboratory finding of more false recall of related words in a PTSD group can be presented as if it showed that people with PTSD misremember their own lives, and a null finding can be presented as if it showed that their accounts are accurate. Neither inference follows. Trauma is not evidence of an unreliable memory, and memory error, where it occurs, is not lying. How stress and emotion shape encoding is addressed in Emotion, Stress, Trauma, and Memory.

What the Laboratory Tasks Measure

Most of the research uses one of two procedures. In the Deese-Roediger-McDermott (DRM) task, a person hears or reads a list of related words (bed, rest, tired, dream) and is later asked to recall or recognize them; the measure of false memory is how often the person reports a strongly associated word that was never presented (sleep). Nearly everyone makes such errors; they are a normal by-product of memory organized by meaning. In the misinformation procedure, a person views an event, often a filmed car accident or other “trauma analogue,” later receives a narrative or questions containing some misleading details, and is then tested on what was in the original event. The measure is how often the suggested details are reported as part of the original.

DRM errors arise from the person’s own associations; misinformation errors require information supplied by someone else, which is closer to the forensic concern about suggestive interviewing. Neither task involves memory for a personal experience of violence or abuse.

False Recall in Trauma-Exposed and PTSD Samples

Several early DRM studies found differences. Zoellner et al. (2000) compared trauma-exposed adults with and without PTSD to adults without trauma exposure; both trauma-exposed groups falsely recalled more critical words than the unexposed group, and false recall was related to trait anxiety and PTSD severity. Bremner et al. (2000) found that women who reported childhood sexual abuse and had PTSD falsely recognized critical words more often (95%) than abused women without PTSD (78%) and nonabused women (79%) and men (86%). The PTSD group also recognized fewer studied words, suggesting a broader difference in task performance. Neither study tested memory for the participants’ own experiences.

Later work suggested that the type of material matters. In a study of 50 Bosnian war survivors with PTSD and 50 war-exposed survivors without it, the two groups were equally prone to false recall of neutral words, but the PTSD group falsely recalled more war-related words; false and correct recall were related more to depression than to self-rated trauma (Brennen et al., 2007). Otgaar et al. (2017) reviewed false-memory studies in people with PTSD, a trauma history, or depression and concluded that these groups showed raised false memory levels when tested with emotional material associated with their concerns, but not consistently with neutral or unrelated material; a comparison of effect sizes across studies supported that distinction. Not all studies fit this pattern. Miano et al. (2022) compared adults with PTSD, adults with borderline personality disorder, and healthy controls on neutral, negative, and disorder-related word lists and found that the PTSD group made fewer false recognitions than controls for neutral words and did not differ on the other lists; the authors concluded that increased false memory in PTSD was not observed in that sample.

A fair summary is that the DRM findings are mixed. Where differences appear, they are modest, tend to involve material related to a person’s concerns, and may reflect anxiety or depression rather than trauma as such.

Misinformation and Suggestibility in Trauma-Exposed Samples

Studies of suggestion, the process more directly relevant to interviewing, have generally not found that trauma or PTSD increases vulnerability. In a community sample tested with a misinformation procedure, neither trauma exposure, PTSD symptoms, nor depressive symptoms predicted acceptance of misleading details, although PTSD symptoms were associated with responses on control items (Jobson et al., 2023). In a study of 243 adults who watched a car-crash film and then heard a summary containing misinformation, participants who reported more distress showed a smaller misinformation effect; the authors attributed this mainly to poorer memory for the accurately summarized items, and they noted that distress was associated with poorer memory accuracy in general (Sharma et al., 2024). In a follow-up with 100 community adults, PTSD symptom severity was not associated with the misinformation effect overall; among participants who had previously experienced a transportation accident, more severe symptoms went with a smaller misinformation effect, and among those who had not, more severe symptoms went with a larger one (Sharma et al., 2026). The authors recommended, if the finding replicates, particular care to avoid suggestive language with people with PTSD who witness an unfamiliar kind of stressful event.

Research with children involved in actual maltreatment investigations points in a similar direction. In a study of 328 children aged 3 to 16 questioned about a medical examination, older age and higher cognitive functioning predicted fewer errors, a history of sexual or physical abuse predicted greater accuracy, and stress hormone levels and trauma symptoms were associated with more errors only among children who reported more dissociative tendencies (Eisen et al., 2007). These findings do not show that trauma-exposed people are immune to suggestion; they show that trauma and PTSD have not been established as markers of greater suggestibility.

Memory for Documented Real Traumas

More direct evidence comes from people whose trauma was independently documented. In a prospective study of 175 people with documented child sexual abuse who had been involved in legal proceedings years earlier, 81% reported the documented abuse when interviewed as adults (Goodman et al., 2003). In the same project, more severe PTSD symptoms were associated with more accurate memory for the abuse 12 to 21 years later, and participants who named the abuse as their most traumatic life event remembered it relatively accurately regardless of PTSD symptoms (Alexander et al., 2005). The researchers also identified predictors of error, such as less maternal support.

These findings are consistent with McNally’s (2003) review of clinical and laboratory evidence, which concluded that traumatic experiences are generally hard to forget, that not thinking about an event for a period should not be confused with an inability to remember it, and that the evidence for repression of trauma is weak. Nothing in the DRM or misinformation research establishes that trauma survivors invent their own histories or are unusually inclined to do so. Where the research does link false memories of trauma to an identifiable condition, that condition is suggestion, particularly in treatment aimed at recovering memories, rather than trauma itself (McNally, 2003; Otgaar et al., 2019).

What Laboratory Proneness Does and Does Not Say About Real Reports

Laboratory and real-world false memories are connected. Lane and Houston (2021, pp. 70–71) note that variables such as repeated imagination raise false memories both for word lists and for autobiographical events, and that individual differences in DRM errors are sometimes greater in people whose autobiographical memories are of questionable authenticity. Several studies illustrate that link. Women who reported recovering memories of childhood sexual abuse were more prone to DRM false recognition than women who had always remembered abuse or had no abuse history (Clancy et al., 2000). People who reported recovered memories of abduction by space aliens, and people who believed they had been abducted but had no memory of it, showed more DRM false recall and false recognition than people who denied abduction, with no difference in correct recall or recognition (Clancy et al., 2002). People who recovered memories of abuse through suggestive therapy showed heightened susceptibility to false memories, while people who recovered memories spontaneously did not, a pattern the authors read as indicating that recovered memories may sometimes be false and sometimes authentic (Geraerts et al., 2009). Lane and Houston (2021, p. 71) also describe a similar finding in people who reported memories of past lives. These are laboratory-susceptibility findings in groups selected for unusual or recovered memories. The alien-abduction and past-life samples are not samples of trauma survivors, and none of these studies examined people with continuous memories of documented trauma.

The connection has limits. People with highly superior autobiographical memory, whose recall of their own lives is highly accurate when checked, are as likely as others, and sometimes more likely, to make DRM and misinformation errors (Lane & Houston, 2021, pp. 71–72). Lane and Houston (2021, p. 73) suggest that the better question is which features a laboratory task shares with a real situation and which it does not. A group’s elevated false recall of related words does not estimate how often that group’s reports of real events are wrong, and it cannot classify an individual’s account.

Treatment-Related Suggestion and Two Positions on Trauma Memory

The research most directly concerned with false memories of trauma involves suggestion. In an age-representative U.S. sample of 2,326 adults, about 9% reported a therapist who had raised the possibility of repressed abuse and about 5% reported recovering abuse memories in therapy; among respondents who had been in therapy, 46.5% (101 of 217) of those whose therapists had discussed repressed abuse reported recovering previously unknown memories of abuse in therapy, compared with 2.3% (19 of 833) of those whose therapists had not (Patihis & Pendergrast, 2019). This is an association in a self-report survey; a survey cannot show cause, or whether any recovered memory was accurate. A recent review found that many therapists understand that memory is malleable while also believing in repression or memory blocking; these beliefs do not necessarily lead to problematic practice but are associated with suggestive techniques, and a minority of therapists still try to recover unremembered trauma despite professional agreement that this should be avoided (Schemmel & Volbert, 2025). For trauma-focused treatments, a review concluded that eye movement desensitization and reprocessing (EMDR) and imagery rescripting can make memories less vivid and less emotionally negative, that the eye movements used in EMDR appear to increase spontaneous false memories but not susceptibility to suggestion, and that findings for imagery rescripting are inconsistent (Otgaar & Houben, 2026). These concerns apply chiefly to attempts to recover memories a person does not have, not to treatment of continuously remembered trauma.

Scientists continue to disagree about trauma memory itself. One position holds that claims of unconsciously repressed trauma lack adequate scientific support, that belief in repression remains common among clinicians, the public, and legal professionals, and that this belief can encourage suggestive practices (Otgaar et al., 2019, 2021). The other position holds that this critique targets a theory of unconscious repression that the major publications in the field do not endorse, that there is an established consensus that recovered memories may be genuine, false, or a mixture, and that recovered memories occur across many forms of therapy, including ones that use no suggestive techniques (Brewin, 2021). Lane and Houston (2021, p. 70) describe the earlier debate as having ended in general agreement that recovered memories are sometimes accurate and sometimes the product of suggestion. A systematic review of 42 studies published since 2000 found reported rates of recovered memory ranging from 1% to 3% in legally documented child sexual abuse samples to 22% to 39% in self-reported survivor samples, depending on definition and sample, and found no cognitive mechanism unique to recovered memories (Carey et al., 2026). Both positions accept that suggestion can produce false memories of trauma; they disagree about whether forgotten trauma involves a special mechanism and how common such forgetting is. Those questions are covered in Recovered and Repressed Memory.

Limits of the Evidence

Most of the laboratory studies are small, many recruit community or student volunteers, and PTSD is often measured by self-report symptom scales rather than clinical diagnosis. Trauma exposure, PTSD, depression, anxiety, and dissociation overlap, and studies differ in which they control. The materials are word lists and filmed events, not personally experienced violence. Effect sizes, where differences appear, are modest, and findings have not been consistent across studies or materials. Women are more likely than men to meet criteria for PTSD, although less likely to experience potentially traumatic events overall (Tolin & Foa, 2006), and several key studies tested only women (Bremner et al., 2000; Clancy et al., 2000), while the misinformation studies included both sexes without reporting sex comparisons. The research reviewed here does not show whether men and women with trauma histories differ in false memory. The studies of documented trauma are more forensically realistic but involve particular samples, chiefly children whose abuse came to the attention of authorities, and they cannot be generalized to every kind of trauma or every witness. No study in this literature can say whether a particular person’s account of a particular event is accurate.

Questions to Ask About This Research

When Bremner et al. (2000) is cited to suggest that a person with PTSD is more prone to false memory, counsel can ask what was counted (recognition of unpresented words, not errors about the person’s own life), whether the PTSD group also performed worse on studied items, and whether later studies, such as Miano et al. (2022), replicated the difference. When Clancy et al. (2000) or Geraerts et al. (2009) are cited, counsel can ask who was studied: groups selected because they reported recovered memories, not people with continuous memories of documented events. When misinformation studies such as Jobson et al. (2023) or Sharma et al. (2024) are offered to show that trauma-exposed witnesses are not more suggestible, counsel can ask whether the participants had clinical PTSD, whether the event was personally experienced, and whether a null group finding says anything about the accuracy of a specific detail. When Alexander et al. (2005) is cited for the accuracy of trauma memory, counsel can ask what predicted errors and how closely the sample resembles the witness.

If treatment-related suggestion is raised, the useful questions are whether there is a record of what was said in treatment, whether the account predates treatment, and whether the techniques were aimed at recovering memories the person had not previously reported. These questions are explained in “Reading Research Claims: A Guide for Attorneys” on this site.

False Memory in Trauma and the Law

Federal and Military Standards

Expert testimony on this research is governed by Federal Rule of Evidence 702, as amended December 1, 2023, which requires the proponent to show that it is more likely than not that the testimony rests on sufficient facts or data, reflects reliable principles and methods, and reflects a reliable application of those methods to the case. Under Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993) the trial judge acts as gatekeeper, Kumho Tire Co. v. Carmichael (1999) extended that obligation to all expert testimony, including non-scientific technical or specialized knowledge, and General Electric Co. v. Joiner (1997) permits exclusion where there is too great an analytical gap between the data and the opinion, as there would be in moving from a group difference on a word-list task to an opinion about a particular witness.

In courts-martial, Military Rule of Evidence 702 tracks the federal rule, and Military Rule of Evidence 1102 generally makes federal amendments applicable eighteen months after their effective date unless the President directs otherwise; the December 1, 2023 amendment took effect in the military rule in 2025 through Military Rule of Evidence 1102 (Joint Service Committee on Military Justice, 2025), and practitioners should confirm current text. United States v. Houser (1993) sets the six-factor test for expert testimony. An expert may not offer an opinion, directly or through statistics, that a witness is truthful or untruthful (United States v. Brooks, 2007). Where a party contends that treatment shaped an account, mental health records may be sought, but communications with psychotherapists are privileged under Military Rule of Evidence 513, subject to its exceptions and procedures; the Court of Appeals for the Armed Forces has held that diagnoses and treatments recorded in medical records are not themselves uniformly privileged (United States v. Mellette, 2022).

Arizona

Arizona Rule of Evidence 702 adopted the Daubert standard in 2012 and was amended effective January 1, 2024 to track the 2023 federal amendment. State v. Salazar-Mercado (2014) permits general, educational expert testimony that satisfies Rule 702 and Rule 403, and State v. Lindsey (1986) and State v. Moran (1986) bar expert opinions on the truthfulness of a particular witness or class of witnesses. When a defendant seeks a victim’s privileged mental health records to explore treatment-related suggestion, in camera review requires a showing of a reasonable possibility, on a sufficiently specific basis rather than speculation, that the records contain information to which the defendant is constitutionally entitled (R.S. v. Thompson, 2021, ¶ 30).

Special Issues in Legal Practice

The principles described above apply with equal force to every party in a legal proceeding. The science operates the same way regardless of who is asking the questions, and the research summarized here does not by itself favor either side. What differs between the parties is not the science but the vantage point — the particular places where these issues tend to surface, and the particular errors each party is best positioned to guard against. The two summaries below identify those recurring issues. They are offered for orientation, not as litigation strategy; in every case the controlling question is what the evidence in that case will, and will not, support, and the expert’s role is to inform the trier of fact rather than to advocate for either side.

Special Issues for Prosecutors

The research supports several propositions prosecutors can legitimately present. A history of trauma or a diagnosis of PTSD does not by itself make a witness unreliable. Laboratory findings of elevated false recall are mixed and do not show that trauma survivors fabricate memories of their own experiences. Recent misinformation studies have generally not found that trauma exposure, PTSD symptoms, or distress increase acceptance of suggested details, and people with documented trauma usually remember it, sometimes with considerable accuracy years later (Goodman et al., 2003; Alexander et al., 2005). Prosecutors are well positioned to protect a trauma-exposed complainant’s account by ensuring that early statements are recorded and that interviews are open-ended and do not supply details.

The research also counsels caution. Null group findings do not establish that a particular account is accurate, and the documented-trauma studies also identified predictors of error. Some studies find more false memories in PTSD groups for material related to a person’s concerns, so trauma-related suggestion in an interview is not harmless simply because the witness has been traumatized. Testimony that trauma memories are indelible or immune to distortion goes beyond the research, and where an account first emerged in treatment aimed at recovering memories, the research on suggestion applies.

Special Issues for Defense

The research supports several propositions defense counsel can legitimately present. Suggestion in interviews and in treatment can produce false memories, including memories of trauma, and in one self-report survey, people whose therapists raised the possibility of repressed abuse were far more likely to report recovering abuse memories (46.5% versus 2.3%; Patihis & Pendergrast, 2019), an association that a survey cannot show to be causal and that says nothing about whether any recovered memory was accurate. Some laboratory studies, though not all, find greater false recall in PTSD groups for emotionally related material, which supports careful scrutiny of whether trauma-related details were supplied to a witness. Expert testimony on these principles, tied to evidence of how and when an account was elicited, can legitimately help the factfinder.

The research also counsels caution about the limits that apply to the defense. The laboratory findings are inconsistent and do not show that trauma survivors in general misremember or invent their experiences; presenting a word-list result as evidence that a witness with PTSD is unreliable misstates the research. Findings from groups selected because they reported recovered memories describe laboratory susceptibility in those groups, not in people who have always remembered their trauma. An expert cannot tell the factfinder that a particular memory is false; the expert analyzes the process (questions, repetition, exposure), not the truth of the account, and concerns about treatment are fairly raised only where there is a factual basis for suggestion in the particular case.

This paper is for educational purposes only and is not legal advice. The author is a psychologist, not an attorney; summaries of law are general and must be verified against current authority or with a licensed attorney.

References

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Brewin, C. R. (2021). Tilting at windmills: Why attacks on repression are misguided. Perspectives on Psychological Science, 16(2), 443–453. https://doi.org/10.1177/1745691620927674

Carey, O. G., Dempsey, M., Minihane, K., & Murphy, G. (2026). When, where, and how often do individuals recover memories of traumatic experiences? A systematic review. Memory, 34(2), 238–259. https://doi.org/10.1080/09658211.2025.2601699

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Legal Authorities

Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).

General Electric Co. v. Joiner, 522 U.S. 136 (1997).

Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999).

R.S. v. Thompson, 251 Ariz. 111, 485 P.3d 1068 (2021).

State v. Lindsey, 149 Ariz. 472, 720 P.2d 73 (1986).

State v. Moran, 151 Ariz. 378, 728 P.2d 248 (1986).

State v. Salazar-Mercado, 234 Ariz. 590, 325 P.3d 996 (2014).

United States v. Brooks, 64 M.J. 325 (C.A.A.F. 2007).

United States v. Houser, 36 M.J. 392 (C.M.A. 1993).

United States v. Mellette, 82 M.J. 374 (C.A.A.F. 2022).

Fed. R. Evid. 702.

Ariz. R. Evid. 702.

Mil. R. Evid. 513.

Mil. R. Evid. 702.

Mil. R. Evid. 1102.

Related topic papers: Emotion, Stress, Trauma, and Memory · Recovered and Repressed Memory · Dissociation and Memory · False Memory · The Misinformation Effect · EMDR and Memory

Related topics from Arizona Forensic Services: Counterintuitive Testimony · Child Abuse Allegations