Investigatory forensic hypnosis was based on a well-intentioned but scientifically untenable position, i.e., that detailed memories could be accurately retrieved and used in criminal investigations. Although anecdotally helpful in some cases, courts recognized the risk that hypnotically elicited memories could pose to the rights of a defendant in a criminal case. Forensic hypnosis was based on untested theories of repression and misdirected conclusions drawn from the pioneering neurosurgical work of Penfield. The works of Orne, Loftus, and other researchers have identified the pitfalls associated with relying on hypnotically retrieved memories, influencing many courts to follow suit in denying the admissibility of such memories. An unfortunate irony of the scientific debate over the validity of hypnotically refreshed memories was that the scientific and judicial discrediting of refreshed memories in a criminal setting preceded the more recent and well-publicized abuse of patients by therapists who used "recovered memory therapy" to retrieve memories of alleged sexual abuse and, in more dramatic cases, "memories" of ritual satanic cult abuse and alien abduction. 38 references