leading the court to declare her testimony inadmissible. The court declared witnesses could not testify if they had used forensic hypnosis as it could alter existing memories in unpredictable ways. However, while this may have been a success for the scientific opposition to the use of forensic hypnosis as evidence, this case would not mark the end of forensic hypnosis's use. In Rock v. Arkansas (1987), Mrs. Rock had been in a fight with her husband when the gun in her hand fired, killing her husband. While she could not initially remember the details of the incident, through hypnosis she claimed to remember that the gun misfired when her husband grabbed her arm. The lower court and Arkansas supreme court corroborated the decision in People v. Shirley regarding hypnotic testimonies; however, the Supreme Court overturned these decisions declaring that a total ban on hypnotic testimonies was unconstitutional and in violation of Mrs. Rock's right to due process (14th amendment) and right to call a witness (6th amendment). The memory wars The United States saw another major increase in the use of forensic hypnosis and its use in courts during the memory wars which took place in the 1980s and 1990s. Young adults in the 1980s, often ones who had used hypnotic therapy services, suddenly began recalling memories of childhood sexual abuse, satanic ritual abuse, and even alien abductions. The spike in appearance of these, often false, memories has been attributed to the popular culture and practitioner supported belief that hypnosis could reveal traumatic memories buried within one's mind. A network of therapists and support groups developed around this trend in the late 1980s. One of the greatest contributors to this trend was that the job of therapists is to comfort their patients and encourage them to confront their abuser; however, this does not allow for the rigorous fact-checking of evidence which courts require. An example of these cases can be seen in Borawick v. Shay (1995) where Borawick accused her aunt of multiple instances of childhood sexual assault after recalling the incident months after undergoing hypnotic age regression. The hypnotist, practicing in California, was not licensed as a psychologist and did not have a medical degree. The court determined that the hypnotic testimony was not admissible as there was no corroborative evidence to support Borawick's memories. The rejection of Borawick's testimony may be a consequence of the creation of the