by her father. maxine broke down under the pressure and had to be psychiatrically hospitalized. she underwent tubal ligation, so she would not have children and repeat the cycle of abuse. with the support of her husband and primary care physician, maxine eventually realized that her memories were false and filed a suit for malpractice. the suit brought to light the mother's manipulation of mental health professionals to convince maxine that she had been sexually abused by her father. in february 1997 maxine berry sued her therapists and clinic that treated her from 1992 to 1995 and, she says, made her falsely believe she had been sexually and physically abused as a child when no such abuse ever occurred. the lawsuit, filed in february 1997 in minnehaha co. circuit court south dakota, states that therapist lynda o'connor-davis had an improper relationship with berry, both during and after her treatment. the suit also names psychologist vail williams, psychiatrist dr. william fuller and charter hospital and charter counseling center as defendants. berry and her husband settled out of court although there have been many legal cases in which false memory appears to have been a factor, this does not ease the process of distinguishing between false memory and real recall. sound therapeutic strategy can help this differentiation, by either avoiding known controversial strategies or to disclosing controversy to a subject. harold merskey published a paper on the ethical issues of recovered-memory therapy. he suggests that if a patient had pre-existing severe issues in their life, it is likely that "deterioration" will occur to a relatively severe extent upon memory recall. this deterioration is a physical parallel to the emotional trauma being surfaced. there may be tears, writhing, or many other forms of physical disturbance. the occurrence of physical deterioration in memory recall coming from a patient with relatively minor issues prior to therapy could be an indication of the recalled memory's potential falsehood. children false memory is often considered for trauma victims including those of childhood sexual abuse. if a child experienced abuse, it is not typical for them to disclose the details of the event when confronted in an open-ended manner. trying to indirectly prompt a memory recall can lead to the conflict of source attribution, as if repeatedly questioned the child might try to recall a memory to satisfy a question. the stress being put on the child can make recovering an accurate memory more difficult. some people hypothesize that as the child continuously attempts to remember a memory, they are building a larger file of sources that the memory could be derived from, potentially including sources other than genuine memories. children that have never been abused but undergo similar response-eliciting techniques can disclose events that never occurred. one of children's most notable setbacks in memory recall is source misattribution. source misattribution is the flaw in deciphering between potential origins of a memory. the source could come from an actual occurring perception, or it can come from an induced and imagined event. younger children, preschoolers in particular, find it more difficult to discriminate between the two. lindsay & johnson (1987) concluded that even children approaching adolescence struggle with this, as well as recalling an existent memory as a witness. children are significantly more likely to confuse a source between being invented or existent. shyamalan, lamb and sheldrick (1995) partially re-created a study that involved attempted memory implanting in children. the study comprised a series of interviews concerning a medical procedure that the children may have undergone. the data was scored so that if a child made one false affirmation during the interview, the child was classified as inaccurate. when the medical procedure was described in detail, "only 13% of the children answered 'yes' to the question 'did you ever have this procedure?'". as to the success of implantation with false 'memories', the children "assented to the question for a variety of reasons, a false memory being only one of them. in sum, it is possible that no false memories have been created in children in implanted-memory studies". ethics and public opinion a 2016 study surveyed the public's attitude regarding the ethics of planting false memories as an attempt to influence healthy behavior. people were most concerned with the consequences, with 37% saying it was overly manipulative, potentially harmful or traumatic. their reasons against are that the ends do not justify the means (32%), potential for abuse (14%), lack of consent (10%), practical doubts (8%), better alternative (7%), and free will (3%). of those who thought implanting false memories would be acceptable, 36% believed the end justified the means, with other reasons being increasing treatment options (6%), people need support (6%), no harm would be done (6%), and it's no worse than alternatives (5%). potential benefits several possible benefits associated with false memory arrive from fuzzy-trace theory and gist memory. valerie f. reyna, who coined the terms as an explanation for the drm paradigm, explains that her findings indicate that reliance on prior knowledge from gist memory can help individuals make safer, well informed choices in terms of risk taking. other positive traits associated with false memory indicate that individuals have superior organizational processes, heightened creativity, and prime solutions for insight based problems. all of these things indicate that false memories are adaptive and functional. false memories tied to familiar concepts can also potentially aid in future problem solving in a related topic, especially when related to survival.