During the past 15 years, police and prosecutors have found a new use for hypnosis. Rather than attempting to hypnotize a witness during a trial, law enforcement officials have used hypnosis before trial to 'refresh' the witness's memory so that he could later testify from personal recollection enhanced by the hypnotic session. To date, courts have adopted four different strategies for resolving the problem of hypnotically restored testimony. Some jurisidctions view hypnosis as analogous to any other means of refreshing a witness's memory. Other recognize the possibility of inaccuracy and therefore admit such evidence only with proof that court-mandated safeguards were followed. Still others prohibit testimony about facts freshly recalled during or subsequent to hypnosis. Finally, a number of jurisdictions prohibit a person who has been hypnotized relating to the matter from testifying about any topic discussed while under hypnosis. Courts are beginning to recognize a systematic pattern of police abuse of forensic hypnosis. Numerous cases have emerged in which it was obvious that hypnosis had been used not to restore memories but to suggest, implant, and fabricate memories favorable to the prosecution. Although some courts have experimented with standards, these have been largely inadequate. Most States have now moved toward the more radical step of prohibiting the use of hypnotically refreshed testimony which is the only appropriate course. The effects of hypnosis on human memory are unpredicatable and uncontrollable. Over 270 notes accompany the test.