Snap Shot
- The question: When can the way a child is questioned lead the child to report things that did not happen, and when can a child’s account be relied on?
- What the research shows: Interviewer bias, leading and repeated questions, reinforcement, and negative stereotypes can produce false reports, most often in preschoolers and when techniques are combined across interviews. Children, including many young children, give accurate accounts to open-ended questions, and protocols such as the NICHD Protocol increase what is obtained through free recall.
- What it does not show: Most studies used minor, non-abusive events and do not show how often real investigations produce false allegations. No test or expert can tell from an account alone whether it was produced by suggestion; an expert analyzes the process (questions, repetition, exposure), not the truth of the account, and a clean recorded interview does not rule out earlier influence.
- The law: Arizona permits general “cold” expert testimony (Salazar-Mercado) but no opinion on a particular child’s credibility (Lindsey, Moran); Rule 702, Houser, and Crawford govern in federal and military courts. Arizona child hearsay is decided under Rules 803 and 807 (State v. Robinson), and 18 U.S.C. § 3509 and Mil. R. Evid. 611(d) govern remote testimony.
- Issues for each side: Prosecutors are best served by recorded interviews, evidence-based protocols, and reliance on volunteered details rather than on detail or confidence; defense counsel should tie specific suggestive techniques to specific details, without treating one suggestive question as proof of taint.
Children are often the only witnesses to offenses against them, and in many child sexual abuse cases the child’s statements are the central evidence. Suggestibility is the degree to which what a child encodes, remembers, and reports can be influenced by social and psychological factors, including the questions asked and what the child is told (Ceci & Bruck, 1993). Research spanning more than a century shows that some ways of questioning can lead children, especially young children, to report events that did not occur. The same research shows that children questioned well can give accurate, useful accounts. Both findings are well supported, and neither cancels the other.
The issue reaches court through taint or reliability hearings, hearsay rulings, expert testimony, and cross-examination of interviewers and parents. One side may argue that suggestive questioning shaped an account; the other, that the child resisted suggestion. The answer depends on the conditions under which the account was obtained.
This paper covers the sources of suggestibility, age trends, techniques that produce false reports, children’s accuracy when interviewed well, the limits of laboratory evidence, and the governing law. Forensic interviewing protocols, question types, repeated interviews, and interview aids such as anatomical dolls are treated in depth in the Child Abuse Allegations resource on this site.
Social and Cognitive Sources of Suggestibility
Early in the twentieth century, Alfred Binet and William Stern found that children’s free narratives were more accurate than their answers to specific or misleading questions, and Binet distinguished errors that reflect a change in memory from errors that reflect yielding to the social pressure of the questioning (Ceci & Bruck, 1993). Research revived in the 1980s, when several day-care prosecutions raised questions about how young children had been interviewed (Ceci & Bruck, 1995).
Binet’s distinction still organizes the field. A cognitive component is an actual change in memory, often a source-monitoring error in which the child attributes to the event something only suggested, overheard, or imagined. A social component is going along with what an adult appears to want, such as agreeing with a leading question to please the interviewer, without any change in memory (Bruck & Ceci, 1999). The two can operate together. Suggestibility is not lying: a suggested detail may be reported sincerely and confidently. Nor is it a fixed trait; it varies with memory strength, delay, question type, the questioner’s status and expectations, and repetition (Bruck & Ceci, 1999).
Age Trends and Individual Differences
Age is among the most consistent predictors. Preschool children, roughly ages 3 to 5, are more suggestible than older children and adults in most research designs, and suggestibility declines through the school years (Bruck & Ceci, 1999; Ceci & Bruck, 1993). Older children and adults are not immune; for false memories that arise spontaneously from the meaning of an experience, older children and adults sometimes err more than younger children (Brainerd et al., 2008).
Within an age group, children differ, but the differences are hard to predict. A synthesis of 69 studies found that language ability and creativity were the cognitive factors most consistently related to suggestibility, but only a minority of all the correlations examined were significant, and no profile reliably identified highly suggestible children (Bruck & Melnyk, 2004). A later review concluded that children with intellectual impairment or limited language skills may be particularly vulnerable (Klemfuss & Olaguez, 2020). These findings describe groups and do not establish whether a particular report is accurate.
How Interviews Introduce Error
The central concept in the modern research is interviewer bias: a prior belief about what happened that shapes which questions are asked, how often, how the suspect is described, and the emotional tone (Ceci & Bruck, 1995). Its effects can accumulate across questions and across interviews.
Question form matters. Open-ended invitations (“Tell me everything that happened”) generally yield accurate, if brief, accounts. Yes/no and forced-choice questions elicit more information with lower accuracy, and when they presuppose facts the child has not reported they can import the interviewer’s assumptions (Bruck & Ceci, 1999). When a question is repeated, a young child may conclude that the earlier answer was not the one wanted: repeating open-ended questions had little effect in one study, but repeating yes/no questions reduced 4-year-olds’ accuracy (Poole & White, 1991). Repeating misleading suggestions across interviews can increase their adoption, depending in part on timing (Melnyk & Bruck, 2004). Repeated interviews that are open-ended and supportive, by contrast, can elicit additional information (Blasbalg et al., 2021).
Bias can also work through reinforcement and social pressure. Preschoolers questioned with techniques documented in the McMartin Preschool investigation, including telling them what other children had supposedly said, praising some answers and disapproving of others, and inviting speculation, made substantially more false allegations about a classroom visitor than children who received suggestive questions alone (Garven et al., 1998).
Stereotype Induction and Interview Atmosphere
Stereotype induction occurs when a child is led to view a person negatively in general terms, which shapes how the child interprets ambiguous events and fills gaps in memory. In the best-known demonstration, the “Sam Stone” study (Leichtman & Ceci, 1995), a man made a brief, uneventful visit to preschool classrooms. The 176 children, aged 3 to 6, were assigned by classroom to a control group; a stereotype group, told stories over the preceding month portraying Sam Stone as clumsy; a suggestion group, interviewed four times with questions implying that he had ripped a book and soiled a teddy bear; or a group that received both. About ten weeks after the visit, a new interviewer asked what had happened. Among 3- and 4-year-olds, no child in the control or stereotype-only group reported a misdeed in free narrative, compared with 21% in the suggestion group and 46% in the combined group (30% of 5- and 6-year-olds in the combined group). In response to direct questions, 72% of the younger combined group’s responses said Sam Stone had done one or both misdeeds and 44% said the child had seen it. When the children were gently challenged, the figure fell to 21%; the article’s wording leaves it unclear whether this, like the 72% and 44%, counts responses or counts children. In the same study, the authors showed videotapes of three children from the combined group to 119 researchers and clinicians who work on children’s testimony at two conferences; the majority could not reliably tell whether the events the children described had occurred (an area under the curve of .52, near chance). The authors themselves called this procedure “clearly not a systematic study” of adults’ judgments, and one 1995 demonstration with three children cannot show how trained forensic interviewers would perform.
Both halves of the result matter. Stereotype plus repeated suggestion produced false reports in a substantial share of the youngest children, some with added detail. Stereotype alone produced no false free-narrative reports, older children were affected much less, and many false assertions fell away under a gentle challenge.
Support should not be confused with suggestion. An accusatory atmosphere can produce false reports, but warmth tends to have the opposite effect. Children aged 3 to 7 questioned about an inoculation by a supportive interviewer made fewer errors on misleading questions than children questioned neutrally (Goodman et al., 1991), and a meta-analysis found that noncontingent support, meaning warmth not tied to particular answers, increased children’s accuracy and resistance to suggestive questions (Saywitz et al., 2019). The concern is reinforcement of particular content, not rapport.
What Children Can Do When Interviewed Well
The National Institute of Child Health and Human Development (NICHD) Investigative Interview Protocol builds an interview around rapport, ground rules, narrative practice, and open-ended invitations. Interviewers using it ask more open-ended and fewer suggestive questions and obtain more information through free recall (Lamb, Orbach, Hershkowitz, Esplin, & Horowitz, 2007); a meta-analysis found similar improvements, with weaker results for preschool children (Benia et al., 2015). In a field study comparing children’s accounts with those of youths who admitted the abuse, details elicited by invitations were more likely to be confirmed than details elicited by focused questions (Lamb, Orbach, Hershkowitz, Horowitz, & Abbott, 2007). Reviews conclude that children’s usefulness as witnesses depends largely on how they are questioned (Brown & Lamb, 2015; Lavoie et al., 2021).
The Revised NICHD Protocol moves rapport building earlier and adds nonsuggestive support for reluctant children. In Israeli field interviews, children were more likely to make allegations under the revised than the standard version (Hershkowitz et al., 2014), and among children who made no allegation in a first interview, closer adherence to the revised protocol in a second interview was associated with allegations (Blasbalg et al., 2021). These studies measured allegations, not verified accuracy.
Recent research extends these findings. In interviews with 112 maltreated children aged 6 to 11, open “wh-” questions about what the child saw, heard, or said produced fewer denials and more new information than paired yes/no questions, though accuracy was not measured (Henderson et al., 2023). In a 2026 analogue study with a staged event, children aged 6 to 7 and 10 to 11 interviewed with the NICHD Protocol reported more correct details than children interviewed under the Memorandum of Good Practice guidelines, mainly through invitations, and the proportion of accurate details was high under both (Pérez Cano et al., 2026). A scoping review found the NICHD Protocol the most studied of 30 interview procedures (Fernandes et al., 2024), and the European Association of Psychology and Law issued research-based recommendations centered on open-ended questioning and avoiding suggestive techniques (Korkman et al., 2025). Lyon and colleagues found that telling reluctant children that an adult had “told me everything” and wanted them to tell the truth (a “putative confession”) increased true disclosures of a staged toy breakage without increasing false reports (Lyon et al., 2014; Rush et al., 2017); these studies concerned a minor staged transgression, and their application to abuse allegations remains to be established.
Low-Stakes Events and the Question of Generalization
Most suggestibility experiments, including the Sam Stone study, involved minor events such as a ripped book or a broken toy. Studies of events involving the child’s own body show more resistance. Among 5- and 7-year-old girls who had a medical checkup, those who had not had a genital examination rarely reported genital touch even to direct or misleading questions, while most who had experienced such touch disclosed it only when asked directly (Saywitz et al., 1991). Among 328 children in maltreatment investigations, older age and higher cognitive functioning predicted fewer errors about a medical examination, and an abuse history was associated with greater, not lesser, accuracy (Eisen et al., 2007).
Critics have argued that the most dramatic findings combined many techniques over many interviews with non-abusive events and say little about how often real interviews produce false allegations or how often abused children fail to disclose (Lyon, 1999). A later review identified unwarranted assumptions on both sides: that children do not make false reports of abuse, and that they are generally unreliable (Ceci et al., 2007). Taken together, the research indicates that under neutral, open-ended questioning most children, including most young children, generally resist misleading suggestions, while under strongly suggestive conditions a meaningful proportion of young children make false reports (Bruck & Ceci, 1999; Ceci et al., 2007); in the Sam Stone study, for example, 21% of the 3- and 4-year-olds in the suggestion group and 46% in the combined stereotype-and-suggestion group gave a false report in free narrative, after four suggestive interviews, with or without a month of stereotyping (Leichtman & Ceci, 1995).
Limits of the Evidence
Most suggestibility studies use preschool and young school-age children from community samples, low-stakes non-abusive events, and interviewers instructed to use specified techniques, and many foundational studies date from the 1990s. Laboratory studies show what can happen, not how often it happens in real investigations; field studies rarely know what happened, so they seldom measure accuracy.
No test, interview analysis, or expert can determine from a child’s statement alone whether it was produced by suggestion; the expert analyzes the process (questions, repetition, exposure), not the truth of the account. A suggestive question does not establish that the answer was false, and a clean recorded interview does not establish that the child was not influenced earlier by a parent, peer, or conversation. Group findings identify risk factors bearing on the weight of particular statements; they cannot say whether a particular child’s memory is accurate.
Questions to Ask About This Research
When the Sam Stone study is cited, counsel should ask what exactly was counted: 72% refers to the younger combined group’s answers to direct questions, not free narratives (46%), and it fell to 21% when the children were challenged, with the article leaving unclear whether that percentage counts responses or children (Leichtman & Ceci, 1995). Counsel should also ask whether its conditions (preschoolers, a month of stereotyping, four suggestive interviews, a minor event) were present. When a protocol interview is offered in support of an account, counsel should ask whether good interviewing shows accuracy or only that one source of error was reduced. When the Revised NICHD Protocol studies (Hershkowitz et al., 2014) or putative-confession studies (Lyon et al., 2014) are cited, counsel should ask whether accuracy was verified and whether the event resembled the allegation. These questions are explained in “Reading Research Claims: A Guide for Attorneys” on this site.
Children’s Suggestibility and the Law
Federal and Military Standards
Expert testimony on children’s suggestibility is governed by Federal Rule of Evidence 702, amended December 1, 2023, to require 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 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.
Idaho v. Wright (1990) held that a young child’s statements to a pediatrician lacked the guarantees of trustworthiness then required, but declined to make recording or the avoidance of leading questions a constitutional requirement. Wright predates Crawford v. Washington (2004), which admits a non-testifying witness’s testimonial statements only if the witness is unavailable and the defendant had a prior opportunity for cross-examination; Whorton v. Bockting (2007) confirmed that the Confrontation Clause does not govern nontestimonial hearsay. Under 18 U.S.C. § 3509, a child is presumed competent, a competency examination requires compelling reasons, and closed-circuit or videotaped testimony may be ordered on findings that the child cannot testify in the defendant’s presence because of fear, a substantial likelihood of emotional trauma, a mental or other infirmity, or conduct of the defendant or counsel. In courts-martial, Military Rule of Evidence 611(d) and R.C.M. 914A permit a child, defined as a person under 16 at the time of testimony, to testify from outside the courtroom in a case involving child abuse or domestic violence, but only if the military judge finds on the record that this is necessary to protect the welfare of the particular child, that the child would be traumatized by the presence of the accused rather than by the courtroom generally, and that the resulting distress would be more than de minimis. New Jersey screens suggestive interviewing directly through a pretrial taint hearing (State v. Michaels, 1994).
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. Under State v. Salazar-Mercado (2014), a “cold” expert may educate the jury about general principles without applying them to the facts, so either party may present general testimony on suggestibility or on children’s capacity to give accurate accounts. Under State v. Lindsey (1986) and State v. Moran (1986), no expert may opine on the truthfulness or accuracy of a particular witness, including whether a child’s account was or was not shaped by suggestion. State v. Robinson (1987) held A.R.S. § 13-1416, a statutory child-hearsay exception, unconstitutional as conflicting with the court-adopted rules of evidence, so child hearsay is decided under the ordinary rules, such as Rule 803(4) and the residual exception in Rule 807; State v. Taylor (App. 1999, ¶¶ 6–11) applied the same reasoning to the recorded-statement statute, A.R.S. § 13-4252.
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. Many young children give accurate accounts in response to open-ended questions; details elicited by invitations were more often confirmed in field research; children often resist suggestions about events involving their own bodies; and an abuse history was associated with greater accuracy in one large sample. The dramatic suggestibility findings came from combined, repeated techniques with very young children and minor events, and an expert can explain, within Salazar-Mercado and Lindsey, that suggestibility depends on the conditions of questioning, not on children as a class.
The research also counsels caution. Where an interviewer began with a firm belief, asked leading or repeated closed questions, told the child what others had said, rewarded particular answers, or described the accused negatively, details first elicited under those conditions are the most open to challenge, and in the studies reviewed here detail, confidence, and emotion were not reliable guides to whether a report was suggested or accurate (for example, the professionals’ judgments in Leichtman & Ceci, 1995). Investigators can prevent the problem by recording every interview, using trained interviewers and an evidence-based protocol, and documenting what the child said first and to whom.
Special Issues for Defense
The research supports careful examination of how an account was obtained. Where the record shows interviewer bias, leading or repeated questioning, reinforcement, social pressure, invitations to speculate, or a negative characterization of the accused, an expert can explain that these are the conditions under which young children have made false reports, and that such reports can be detailed, sincerely held, and, in the studies reviewed here, hard for professionals to distinguish from accurate ones. Counsel can trace which details first appeared in response to which questions and what the child had heard beforehand.
The research also counsels caution. The strongest effects came from combined techniques with preschool children and low-stakes events; one suggestive question in an otherwise open interview does not establish that an account was produced by suggestion, older children are much less affected, and in the Sam Stone study many false assertions fell away under challenge. Rapport is not suggestion. The argument is most persuasive when it links specific techniques to specific details, and an expert may not opine that a particular account is false.
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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Henderson, H. M., Lundon, G. M., & Lyon, T. D. (2023). Suppositional wh-questions about perceptions, conversations, and actions are more productive than paired yes-no questions when questioning maltreated children. Child Maltreatment, 28(1), 55–65. https://doi.org/10.1177/10775595211067208
Hershkowitz, I., Lamb, M. E., & Katz, C. (2014). Allegation rates in forensic child abuse investigations: Comparing the revised and standard NICHD protocols. Psychology, Public Policy, and Law, 20(3), 336–344. https://doi.org/10.1037/a0037391
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Legal Authorities
Crawford v. Washington, 541 U.S. 36 (2004).
Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).
Idaho v. Wright, 497 U.S. 805 (1990).
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999).
State v. Lindsey, 149 Ariz. 472, 720 P.2d 73 (1986).
State v. Michaels, 136 N.J. 299, 642 A.2d 1372 (1994).
State v. Moran, 151 Ariz. 378, 728 P.2d 248 (1986).
State v. Robinson, 153 Ariz. 191, 735 P.2d 801 (1987).
State v. Salazar-Mercado, 234 Ariz. 590, 325 P.3d 996 (2014).
State v. Taylor, 196 Ariz. 584, 2 P.3d 674 (App. 1999).
United States v. Houser, 36 M.J. 392 (C.M.A. 1993).
Whorton v. Bockting, 549 U.S. 406 (2007).
U.S. Const. amend. VI.
18 U.S.C. § 3509.
Ariz. Rev. Stat. Ann. § 13-1416 (held unconstitutional in State v. Robinson).
Ariz. Rev. Stat. Ann. § 13-4252 (held unconstitutional in State v. Taylor).
Fed. R. Evid. 702.
Ariz. R. Evid. 702.
Ariz. R. Evid. 803.
Ariz. R. Evid. 807.
Mil. R. Evid. 611(d).
Rule for Courts-Martial 914A.
Mil. R. Evid. 702.
Mil. R. Evid. 1102.
Related topic papers: Memory Development · The Misinformation Effect · False Memory · Source Monitoring · Imagination Inflation · Children’s Face Recognition
Related topics from Arizona Forensic Services: Child Abuse Allegations · False Confessions: Suggestibility · Courts-Martial