The amicus brief in the Kelly Michaels case ignores the risks that abused children will fail to reveal abuse unless direct and sometimes leading questions are asked. Although the brief correctly criticizes previous research for understating the risks that aggressive interviewing practices will lead young children to make false allegations of abuse, it overstates the likelihood that false allegations occur by overlooking the aspects of the Kelly Michaels case and the research it inspired that are unlike the typical abuse case.  The author discusses factors that lead abused children to falsely deny abuse and that minimize the likelihood that nonabused children will allege abuse.