An examination of existing relevant studies shows there is more scientific evidence of the possibility of accurate delayed (or "repressed") recall of childhood abuse than there is of the possibility of creating full-blown false memories of sexual abuse. Still, there is adequate evidence that some people may create unfounded memories of childhood sexual abuse, either under pressure from heavy-handed suggestive techniques or possibly through some deterioration of source memory. There are no studies that directly document this phenomenon, nor have any studies revealed whether indirect questioning by nonfamily members is likely to have the same effect as heavy-handed suggestion. Available evidence from analogous situations and anecdotes, however, suggests at least that direct and heavy-handed techniques can induce some individuals to adopt as true memories events that did not occur. Overall, the evidence suggests the wisdom of courts adopting a balancing approach in each case rather than an "on/off" or "black/white" approach. In balancing or weighing delayed recall testimony, courts and juries should consider all available information and circumstances, giving each case the attention required to achieve justice both for those accused and for victims of child abuse. This would involve careful inquiries into the circumstance surrounding the return of the memories as well as consideration of all other evidence that contributes to an overall assessment of the credibility of the recollections. 38 notes