The Kennedy case might be thought to indicate that foundationalist and coherentist accounts of the justification of memory belief share a common flaw: they are both (at least as typically construed) synchronic rather than diachronic theories.  They make the justificatory status of a memory a belief purely a function of the current, internal state of the person at the time in question.  Put somewhat differently, the only properties relevant to the justification of my belief are my current, non-historical properties. But, arguably, what the Kennedy case shows is that, in at least some circumstances, whether a memory belief is justified now is partially dependent on whether it was justified earlier. 