Repression is a psychological defense mechanism that protects the individual from being confronted with the memory of an event that is too traumatic to cope with. Physiological research conducted on the functioning of memory demonstrates the brain's biological capacity to retain memories yet prevent conscious access to them. The memory is not lost but remains dormant and inaccessible. The individual functions with no conscious awareness of the traumatic event. Researchers and clinicians attest that the inaccessible memory may nonetheless adversely impact the individual's psychological well-being and is frequently manifested by substance abuse, severe depression, suicidal tendencies, and sexual and social dysfunctions.
Repressed memories are, however, only temporarily inaccessible.
The brain is capable of retrieving previously inaccessible memory in response to stimuli. These stimuli, commonly referred to as triggers, include sensory experiences, therapy, and spontaneous recall. The court observed that repressed memory has been demonstrated empirically in cases of childhood sexual abuse, and studies suggest that the probability of memory repression increases with the severity of the sexual abuse. The court also noted that repressed memory is not accepted by all psychologists and is criticized by others who believe these are false memories implanted by inadequately trained or unethical therapists. The court pointed out that it appeared that P's retrieval of the repressed memories of her father's abuse was not triggered by therapy.