Snap Shot
- The question: How does memory change between late childhood and early adulthood, how suggestible are adolescents compared with younger children and adults, and what does that mean for adolescent witnesses and for later recall of the teenage years?
- What the research shows: Episodic memory, source memory, and the brain systems that support them continue to mature into adolescence, and pubertal development has measurable effects on those systems apart from age. Suggestibility under neutral questioning declines from the preschool years, and adolescents interviewed with open-ended questions can give detailed, accurate accounts. Some meaning-based false memories increase with age, and adolescents aged 12 to 16 were more likely than young adults to accept responsibility under false evidence in a laboratory task. The adolescent years later supply an unusually large share of adults’ autobiographical memories.
- What it does not show: The research does not show that a particular adolescent’s account is accurate or inaccurate, that pubertal brain changes make adolescent memories unreliable, or that memories from adolescence are accurate because they are numerous or vivid. Research on how best to interview adolescents is recent and largely descriptive.
- The law: Rule 702 and Houser govern memory testimony; adolescents are presumed competent to testify (Rule 601), and a young person’s age informs the Miranda custody analysis (J.D.B.). In Arizona, Rule 702, Chapple, and Nordstrom govern, and under Lindsey no expert may say whether a particular witness’s memory is accurate.
- Issues for each side: Prosecutors can present adolescents’ capacity to give accurate accounts under good questioning, without presenting adolescent memory as immune to peer influence or suggestion; defense counsel can raise suggestion, peer contamination, and pressure from authority figures, without importing preschool suggestibility findings or implying that teenage accounts are generally unreliable.
Adolescence, roughly the years from the onset of puberty to the early twenties, is a period of continued change in memory. Children enter it able to remember and report a great deal, but the ability to bind the details of an event to its time, place, and source, to organize personal experience into a coherent life story, and to resist pressure from adults and peers continues to develop. Puberty itself is accompanied by changes in the brain regions that support memory, changes that research can now separate in part from the effects of chronological age.
These questions reach court in two ways. Adolescents are frequently witnesses and complainants, particularly in sexual offense cases, and are sometimes suspects, so counsel and courts must evaluate accounts given by people whose memory and social judgment are still maturing. Adults also testify, sometimes decades later, about events from their teenage years, and the adolescent years turn out to be unusually well represented in adult memory. The second topic is treated in depth in the companion paper, The Reminiscence Bump; this paper concentrates on memory during adolescence itself.
This paper summarizes research on memory development across adolescence, the effects of puberty, suggestibility and compliance in adolescents compared with children and adults, and the interviewing of adolescent witnesses, and it describes briefly how adolescent experience becomes the reminiscence bump of later life. It then reviews the limits of the evidence and the federal, military, and Arizona law that governs testimony on these subjects. Memory before adolescence is covered in Memory Development and Childhood Amnesia, and suggestibility in younger children in Suggestibility of Children’s Memory.
Memory Development Through Adolescence
By the early school years children can remember and report experienced events in considerable detail, but several components of memory continue to improve. A theoretical review integrating behavioral and imaging research proposed that early in development the memory system emphasizes generalization, extracting what recurring events have in common and building knowledge, at the expense of storing the specific details that distinguish one episode from another; that emphasis persists into middle childhood and possibly into adolescence, and the authors linked the gradual shift toward specificity to differences in the maturation of subregions of the hippocampus (Keresztes et al., 2018). If that account is correct, the practical implication for interviewers, which the review itself does not test, is that an older child or adolescent may describe what usually happened with confidence and accuracy while having more difficulty attaching a particular detail to a particular occasion.
Imaging research shows that the brain systems supporting episodic memory continue to change after early childhood. A review focused on middle childhood described continued development of the hippocampus and of the prefrontal regions that support the strategic search, monitoring, and evaluation of memories, and linked those changes to improvements in remembering the contextual details of events (Ghetti & Bunge, 2012). These are group-level developmental trends. They describe how average performance changes with age, not a threshold below which memory is unreliable.
Adolescence is also when autobiographical memory takes on its adult organization. Habermas and Bluck (2000) reviewed evidence that the cognitive tools needed to construct a coherent life story, including the ability to place events in temporal and causal sequence and to draw connections between experiences and one’s own identity, develop during adolescence, together with the social motivation to tell such a story. That development helps explain why events from adolescence later occupy a central place in adults’ accounts of their lives.
Puberty and the Developing Memory System
Puberty is a neural as well as a hormonal and physical transition. In a longitudinal study of 711 magnetic resonance imaging scans from 275 individuals aged 7 to 20, pubertal development was related to the volume of the hippocampus, the amygdala, and several other subcortical structures in both sexes, and puberty and age had independent as well as combined effects on hippocampal and amygdala volume (Goddings et al., 2014). In a longitudinal functional imaging study of children aged 8 to 14 performing a task that required remembering which context an item had appeared in, hippocampal activation during successful retrieval followed a nonlinear course across childhood and early adolescence, prefrontal activation increased rapidly, and changes in pubertal status, measured by questionnaire and by salivary testosterone, predicted changes in memory-related activation independent of age (Selmeczy et al., 2019).
These findings support a modest conclusion: pubertal timing contributes to how the memory system develops, so two adolescents of the same age may differ in the maturity of the systems that support detailed episodic memory. They do not show that adolescents’ memories are less accurate during puberty, and they do not provide a measure that can be applied to an individual witness. Brain volume and activation are correlates of memory performance, not tests of the accuracy of a particular memory, and this line of research is still developing.
Puberty may also leave a trace in later recall. In a large online study in which almost 2,000 participants aged 11 to 70 recalled and dated memories in response to cue words, the peak of the reminiscence bump fell at about ages 13 to 14 for women and 15 to 18 for men (Janssen et al., 2005). Because girls on average enter puberty earlier than boys, some writers have connected the earlier peak in women to pubertal timing. The study did not measure puberty, however, and the connection is an interpretation rather than a finding.
Suggestibility and Compliance Across Adolescence
On most laboratory measures, susceptibility to suggestive questioning declines with age, and the largest age differences involve preschool children (Ceci & Bruck, 1993). Older children and adolescents generally resist misleading questions better than younger children, and when questioned with open-ended prompts they generally provide accurate information. In a longitudinal study in which children took part in a mildly distressing event at ages 3 to 5 and were reinterviewed six to seven years later at ages 9 to 12, memory was less accurate after the long delay, but children who were older at the second interview were less suggestible, and misinformation introduced at the first interview did not contaminate the children’s free recall years later (Gonzalves et al., 2022). Research on preschool children’s suggestibility therefore should not be applied to adolescents without qualification.
The developmental story is not simply that memory errors decline with age. A review of research on false memories rooted in meaning, in which a person remembers something that fits the gist of what was experienced but did not occur, found that such errors often increase from childhood into adolescence and adulthood, because the ability to extract meaning connections among events also increases (Brainerd et al., 2008). Adolescents are therefore subject to the same meaning-based and schema-driven errors as adults. They are also subject to the social influences that affect adult witnesses: in adult studies, people who discussed an event with another witness frequently reported details they could only have learned from that person (Gabbert et al., 2003), and although that research was conducted with adults, it bears on any case in which adolescents discussed an event with peers before giving an account.
Social pressure from authority figures raises a separate issue. In a laboratory experiment in which participants were falsely told they had caused a computer to crash, 12- and 13-year-olds and 15- and 16-year-olds were more likely than young adults to accept responsibility for something they had not done, particularly when presented with false evidence, and more suggestible participants were more likely to do so (Redlich & Goodman, 2003). In a cross-sectional study of more than 5,000 participants aged 10 to 30 in eleven countries, general cognitive capacity reached adult levels around age 16, while psychosocial maturity, including impulse control, continued to develop into early adulthood (Icenogle et al., 2019). These studies concern compliance and decision making under pressure, not memory for an event, but they bear on how adolescents respond to leading or accusatory questioning, whether as witnesses or as suspects. The False Confessions resources on this site address suspect interviews in detail.
Interviewing Adolescent Witnesses
Structured, open-ended interviewing has the strongest research support for young witnesses. A review of research on the NICHD Investigative Interview Protocol, which emphasizes rapport, practice in narrative recall, and open-ended invitations, concluded that its use substantially improved the quality of interviews with children (Lamb et al., 2007). The samples in that research were weighted toward younger children, and adolescents present some distinct challenges. In an Australian police sample of 527 children aged 3 to 16 who were offered a forensic interview, disclosure increased with age until about 11 and then decreased through age 16, and adolescents who alleged abuse by suspects with violent histories were among the groups least likely to disclose (Leach et al., 2017).
Recent research has begun to address adolescents directly. A systematic review found that only one study since 1990 had experimentally tested techniques for building rapport with adolescents, and that most rapport strategies used with children and adults had not been tested with this age group (Dianiska et al., 2024). In interviews with expert forensic interviewers, adolescents were described as frequently reluctant to disclose, and the interviewers’ strategies centered on treating each adolescent as a relatively autonomous person (Deck et al., 2025); a related study described how expert interviewers approach adolescents who are reluctant to disclose sexual abuse (Gerryts et al., 2025). These studies report experienced practitioners’ views; they identify promising approaches for testing rather than validated techniques.
The research supports two points that apply to both sides. An adolescent questioned with open-ended prompts, without pressure, and before extensive discussion with others is capable of an accurate and detailed account. An adolescent’s account may also reflect earlier conversations with peers, parents, or school staff, reluctance to reveal disapproved behavior, or deference to adult questioners, and those influences are evaluated through the record of what was said and asked, not presumed from the witness’s age.
From Adolescence to the Reminiscence Bump
What happens in adolescence has consequences for memory decades later. Adults past midlife recall a disproportionate share of their personal memories from roughly ages 10 to 30, a pattern called the reminiscence bump (Rubin et al., 1986), while memories from the first years of life are scarce because of childhood amnesia: the average adult’s earliest memory dates to about three to three and a half years, and very few reliable memories date from before age two. The developmental changes described above, including the emergence of the life story in adolescence (Habermas & Bluck, 2000), are among the reasons proposed for why the adolescent and early adult years are later recalled so readily.
For legal purposes, the bump means that an adult who recalls substantial detail from adolescence is doing what memory research would predict, and that the passage of decades does not by itself mean that memories from the teenage years have been lost. It does not mean that those memories are accurate in their details, and memories from early childhood remain subject to the constraints described in Childhood Amnesia. The distinction between how much a person remembers and whether a particular memory is accurate, along with the effect of cueing methods, emotional valence, and dating errors, is the subject of The Reminiscence Bump.
Limits of the Evidence
Most of the research summarized here is laboratory research with community or student samples, mildly stressful or neutral events, and low personal stakes. Imaging studies involve modest samples relative to the variability among adolescents, and their measures of brain structure and activation are correlates of memory performance, not indicators of the accuracy of any memory. Much of the research on co-witness influence and intoxication that bears on adolescent cases was conducted with adults and is extrapolated to adolescents. Research on forensic interviewing of adolescents is recent and largely based on practitioners’ reports. Age is an imperfect proxy for development: pubertal timing, cognitive ability, disability, and life experience vary widely among adolescents of the same age. Group research can describe what tends to happen under given conditions; it cannot establish whether a particular adolescent’s account, or a particular adult’s memory of adolescence, is accurate.
Questions to Ask About This Research
When imaging studies such as Goddings et al. (2014) or Selmeczy et al. (2019) are cited to argue that memories laid down during puberty are untrustworthy, counsel should ask whether the conclusion follows from the design, because those studies measured brain volume and activation during laboratory tasks, not the accuracy of memories for real events. When Redlich and Goodman’s (2003) finding that adolescents aged 12 to 16 more often accepted responsibility under false evidence is cited, counsel should ask what exactly was measured and who was studied: a laboratory admission of crashing a computer, not memory for a witnessed event, so the finding speaks to compliance under pressure rather than to the accuracy of a complainant’s recollection. When the reduced suggestibility of older children (Ceci & Bruck, 1993; Gonzalves et al., 2022) is cited to support an adolescent’s account, counsel should ask whether the finding applies to this person, given how this adolescent was questioned and what he or she discussed with others beforehand. When the sex difference in the peak of the reminiscence bump (Janssen et al., 2005) is offered to assign a memory to the years before or after puberty, counsel should ask whether a group average, in a study that did not measure puberty, applies to this person. These questions are explained in “Reading Research Claims: A Guide for Attorneys” on this site.
Memory Across Puberty and the Law
Federal and Military Standards
Every person is competent to be a witness unless the rules provide otherwise (Fed. R. Evid. 601; Mil. R. Evid. 601), so an adolescent’s age goes to the weight of the testimony rather than to its admissibility. Expert testimony about adolescent memory and suggestibility 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 them to the case. Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993) makes the trial judge a gatekeeper, and Kumho Tire Co. v. Carmichael (1999) extends that obligation to all expert testimony, including non-scientific technical or other specialized knowledge. In courts-martial, Military Rule of Evidence 702 tracks the federal rule; the 2023 amendment took effect in the military rule in 2025 through Military Rule of Evidence 1102 (Joint Service Committee on Military Justice, 2025; practitioners should confirm current text), and United States v. Houser (1993) sets out six admissibility factors, including the expert’s qualifications, the relevance and reliability of the testimony, and its probative value. When an adolescent is a suspect, the Supreme Court has held that a child’s age, if known to the officer or objectively apparent, properly informs the Miranda custody analysis (J.D.B. v. North Carolina, 2011).
Arizona
Arizona Rule of Evidence 601 likewise presumes competence. Arizona Rule of Evidence 702 adopted the Daubert standard effective January 1, 2012, and was amended effective January 1, 2024, to track the 2023 federal amendment (Ariz. Sup. Ct. Order R-23-0004). State v. Chapple (1983) is Arizona’s leading case on expert testimony about memory, holding that exclusion of eyewitness memory testimony was an abuse of discretion on its facts, and State v. Nordstrom (2001) confirmed that admission otherwise remains within the trial court’s discretion. Under State v. Lindsey (1986), an expert may describe general patterns relevant to child and adolescent witnesses but may not opine, directly or by implication, on whether a particular witness is truthful or whether a particular account is accurate, and State v. Moran (1986) applied the same limit; those limits apply to testimony offered by either side.
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. On most laboratory measures, susceptibility to suggestive questioning declines with age (Ceci & Bruck, 1993; Gonzalves et al., 2022), and an adolescent questioned with open-ended prompts can give a detailed and accurate account. Reluctance, delay, and incomplete early accounts are commonly described among adolescents and do not by themselves indicate that an account is inaccurate. Where an adult testifies about events from adolescence, the reminiscence bump explains why substantial memory from those years may remain after a long delay. Prosecutors are well positioned to protect the value of an adolescent’s account by ensuring that the first formal interview is recorded, uses open-ended questions, and documents what the adolescent had already discussed with peers, parents, and others.
The research also counsels caution. Adolescents are subject to adult-like meaning-based errors and to co-witness influence, and peer conversation before a first interview is common in adolescent cases. Younger adolescents are more likely than adults to defer to authority under pressure, which bears on how both complainants and suspects were questioned. Expert testimony that an adolescent’s memory is reliable because of his or her age, or that an adult’s memory of adolescence is accurate because it dates from the years of the reminiscence bump, goes beyond the research and risks the problem identified in Lindsey.
Special Issues for Defense
The research supports several propositions defense counsel can legitimately present. Memory for the specific details that distinguish one occasion from another, and for the source of information, continues to develop into adolescence. Adolescents are susceptible to meaning-based false memories and to information from peers, and younger adolescents are more likely than adults to comply with pressure from authority, including false-evidence tactics. Expert testimony explaining these principles, combined with evidence of what an adolescent heard, discussed, and was asked before giving an account, is a legitimate way to help the factfinder evaluate that account, and the same principles bear on statements obtained from adolescent suspects.
The research also counsels caution about the limits that apply to the defense. The large suggestibility effects found with preschool children do not transfer to adolescents without qualification, and older children generally resist misleading questions better than younger ones. Pubertal brain research does not show that adolescent memories are unreliable. Reluctance, delay, and later additions to an account are common in adolescent disclosures and are not, by themselves, signs of fabrication. Testimony implying that teenage accounts are generally untrustworthy is unsupported, and an expert may not tell the factfinder that a particular account was shaped by suggestion.
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
Brainerd, C. J., Reyna, V. F., & Ceci, S. J. (2008). Developmental reversals in false memory: A review of data and theory. Psychological Bulletin, 134(3), 343–382. https://doi.org/10.1037/0033-2909.134.3.343
Ceci, S. J., & Bruck, M. (1993). Suggestibility of the child witness: A historical review and synthesis. Psychological Bulletin, 113(3), 403–439. https://doi.org/10.1037/0033-2909.113.3.403
Deck, S. L., Quas, J. A., & Powell, M. B. (2025). Unique considerations for forensic interviews with adolescents: An exploration of expert interviewers’ perspectives. Child Maltreatment, 30(2), 229–241. https://doi.org/10.1177/10775595241270046
Dianiska, R. E., Quas, J. A., & Lyon, T. D. (2024). Using rapport building to improve information yield when interviewing adolescents: A systematic review and call for research. Child Abuse & Neglect, 154, Article 106898. https://doi.org/10.1016/j.chiabu.2024.106898
Gabbert, F., Memon, A., & Allan, K. (2003). Memory conformity: Can eyewitnesses influence each other’s memories for an event? Applied Cognitive Psychology, 17(5), 533–543. https://doi.org/10.1002/acp.885
Gerryts, D. D., Deck, S. L., & Powell, M. B. (2025). Expert interviewers’ approach to navigating forensic interviews with adolescents who are reluctant to disclose sexual abuse. Psychiatry, Psychology and Law, 32(6), 879–897. https://doi.org/10.1080/13218719.2024.2362134
Ghetti, S., & Bunge, S. A. (2012). Neural changes underlying the development of episodic memory during middle childhood. Developmental Cognitive Neuroscience, 2(4), 381–395. https://doi.org/10.1016/j.dcn.2012.05.002
Goddings, A.-L., Mills, K. L., Clasen, L. S., Giedd, J. N., Viner, R. M., & Blakemore, S.-J. (2014). The influence of puberty on subcortical brain development. NeuroImage, 88, 242–251. https://doi.org/10.1016/j.neuroimage.2013.09.073
Gonzalves, L., Chae, Y., Wang, Y., Widaman, K. F., Bederian-Gardner, D., Goodman-Wilson, M., Thompson, R. A., Shaver, P. R., & Goodman, G. S. (2022). Children’s memory and suggestibility years later: Age, distress, and attachment. Applied Cognitive Psychology, 36(5), 1034–1048. https://doi.org/10.1002/acp.3988
Habermas, T., & Bluck, S. (2000). Getting a life: The emergence of the life story in adolescence. Psychological Bulletin, 126(5), 748–769. https://doi.org/10.1037/0033-2909.126.5.748
Icenogle, G., Steinberg, L., Duell, N., Chein, J., Chang, L., Chaudhary, N., Di Giunta, L., Dodge, K. A., Fanti, K. A., Lansford, J. E., Oburu, P., Pastorelli, C., Skinner, A. T., Sorbring, E., Tapanya, S., Uribe Tirado, L. M., Alampay, L. P., Al-Hassan, S. M., Takash, H. M. S., & Bacchini, D. (2019). Adolescents’ cognitive capacity reaches adult levels prior to their psychosocial maturity: Evidence for a “maturity gap” in a multinational, cross-sectional sample. Law and Human Behavior, 43(1), 69–85. https://doi.org/10.1037/lhb0000315
Janssen, S. M. J., Chessa, A. G., & Murre, J. M. J. (2005). The reminiscence bump in autobiographical memory: Effects of age, gender, education, and culture. Memory, 13(6), 658–668. https://doi.org/10.1080/09658210444000322
Joint Service Committee on Military Justice. (2025). Amendments to the Military Rules of Evidence since 1984 (G. E. Maggs, Ed.; 2025 ed.). https://jsc.defense.gov/Portals/99/MRE%20Amendments%202025.pdf
Keresztes, A., Ngo, C. T., Lindenberger, U., Werkle-Bergner, M., & Newcombe, N. S. (2018). Hippocampal maturation drives memory from generalization to specificity. Trends in Cognitive Sciences, 22(8), 676–686. https://doi.org/10.1016/j.tics.2018.05.004
Lamb, M. E., Orbach, Y., Hershkowitz, I., Esplin, P. W., & Horowitz, D. (2007). A structured forensic interview protocol improves the quality and informativeness of investigative interviews with children: A review of research using the NICHD Investigative Interview Protocol. Child Abuse & Neglect, 31(11–12), 1201–1231. https://doi.org/10.1016/j.chiabu.2007.03.021
Leach, C., Powell, M. B., Sharman, S. J., & Anglim, J. (2017). The relationship between children’s age and disclosures of sexual abuse during forensic interviews. Child Maltreatment, 22(1), 79–88. https://doi.org/10.1177/1077559516675723
Redlich, A. D., & Goodman, G. S. (2003). Taking responsibility for an act not committed: The influence of age and suggestibility. Law and Human Behavior, 27(2), 141–156. https://doi.org/10.1023/A:1022543012851
Rubin, D. C., Wetzler, S. E., & Nebes, R. D. (1986). Autobiographical memory across the lifespan. In D. C. Rubin (Ed.), Autobiographical memory (pp. 202–221). Cambridge University Press.
Selmeczy, D., Fandakova, Y., Grimm, K. J., Bunge, S. A., & Ghetti, S. (2019). Longitudinal trajectories of hippocampal and prefrontal contributions to episodic retrieval: Effects of age and puberty. Developmental Cognitive Neuroscience, 36, Article 100599. https://doi.org/10.1016/j.dcn.2018.10.003
Legal Authorities
Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).
J.D.B. v. North Carolina, 564 U.S. 261 (2011).
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999).
State v. Chapple, 135 Ariz. 281, 660 P.2d 1208 (1983).
State v. Lindsey, 149 Ariz. 472, 720 P.2d 73 (1986).
State v. Moran, 151 Ariz. 378, 728 P.2d 248 (1986).
State v. Nordstrom, 200 Ariz. 229, 25 P.3d 717 (2001).
United States v. Houser, 36 M.J. 392 (C.M.A. 1993).
Fed. R. Evid. 601.
Fed. R. Evid. 702.
Ariz. R. Evid. 601.
Ariz. R. Evid. 702.
Ariz. Sup. Ct. Order R-23-0004 (amending Ariz. R. Evid. 702, effective Jan. 1, 2024).
Mil. R. Evid. 601.
Mil. R. Evid. 702.
Mil. R. Evid. 1102.
Related topic papers: The Reminiscence Bump · Memory Development · Childhood Amnesia · Suggestibility of Children’s Memory · Aging and Memory · The Telescoping Effect
Related topics from Arizona Forensic Services: Child Abuse Allegations · False Confessions: Suggestibility