Only in the past 15 years has evidence obtained under hypnosis been allowed in the courtroom. Perhaps the first use of hypnotism was in 1968, when testimony under hypnosis by a murder defendant resulted in a charge reduction and a guilty verdict for assault. In 1979, evidence obtained under hypnosis was rules inadmissible on the grounds that questions were poorly phrased and the defendant was in a state of disinhibition. In a subsequent 1981 trial, the judge held that hypnosis had advanced sufficiently to be considered a scientific method and that recalled evidence could be admitted. In general, difficulties with the use of hypnosis stem from difficulties in defining its boundaries and controlling it. Consequently, it is suggested that guidelines for investigative hypnosis be developed and followed. 13 references.