In 1995, the Ninth Circuit Court of Appeals ruled, in Franklin v. Duncan and Franklin v. Fox, Murray
et al. (312 F3d. 423, see also 884 FSupp 1435, N.D. Calif.),
[78] that repressed memory is not admissible as evidence in a legal action because of its unreliability, inconsistency, unscientific nature, tendency to be therapeutically induced evidence, and subject to influence by hearsay and suggestibility.