Since the 1980s the place of repressed memory in the judicial system has remained one of the most controversial issues. There has been counter argument regarding the validity of repressed. Repressed memory is the memory of experience from a trauma that one recalls after a very long period, usually under the guidance of a counselor. Today there are few cases presented in courts based on repressed memory than it was during 1980s. There are number of reasons which have led to decreased admissibility of repressed memory as evidence in courts. First, research shows that people have used repressed memory to gain financially with therapist being accused of memory manipulation to gain financially. Second a wide range of research data has faulted reliability of repressed memory due to lack of scientific methods to prove it. Third, it has become difficult to distinguish between false memories and true memories. These reasons and others show why there has been reduced court cases based on repressed memory. Therefore repressed memory should not be used in courts.