This week, a Massachusetts court ordered Misha Defonseca, author of the fraudulent memoir Misha: A Memoir of the Holocaust Years, to repay her publisher some $22 million. The news made headlines because of the staggering amount of money involved: The author and her publisher had been embroiled in a series of court battles over royalties for years (though it seems unlikely that even a successful and widely translated book like Misha could possibly have brought in millions).

But without the huge sums at stake, it’s unlikely that the case would have come back into the news. For the odd fact is that writing a fake Holocaust memoir has become, by now, a dog-bites-man story. Misha Defonseca is just the latest example of a genre that also includes Herman Rosenblat, author of the Oprah-endorsed Angel at the Fence—whose fraud was first exposed by The New Republic—and Benjamin Wilkomirski, author of Fragments: Memories of a Wartime Childhood.

Each of these books was popular and celebrated, before knowledgeable readers began to raise questions about their incredible details. In the end, each author had to retract his or her creation. Defonseca, it turned out, did not actually survive the Holocaust by taking shelter among a pack of wolves; indeed, she was not even Jewish, but a Belgian Catholic who spent the war years going to school. Rosenblat did not survive Buchenwald thanks to a girl who threw apples and bread to him over the camp fence—and then, years later, became his wife. And Wilkomirski, far from spending the war years in concentration camps in Poland, was actually a Swiss native named Bruno Grosjean, whose childhood was spent in a Swiss orphanage.

If the fake Holocaust memoir is by now a genre of its own, the godfather of that genre would have to be Jerzy Kosinski, whose novel The Painted Bird, published in 1965, was one of the first Holocaust stories to be first celebrated and then attacked as fictional. Of course, in Kosinski’s case, the book actually was a fiction: He always insisted The Painted Bird was a novel, not an autobiography. Yet he and his publisher deliberately blurred the line between the two genres, cultivating the idea that the experiences of the book’s unnamed child narrator were really Kosinski’s own. In time, more charges were brought against Kosinski, including the suggestions that he had plagiarized The Painted Bird from various Polish sources, and even that the book was not written by him at all, but the product of a ghostwriter.

The Painted Bird set the pattern for the fake Holocaust story in several ways. First, by making the author’s childhood self the protagonist and narrator, such stories claim the mantle of some of the undoubted classics of Holocaust literature, such as Elie Wiesel’s Night. More, they immunize themselves against accusations of inaccuracy: Who, after all, can vouch for the truth of every one of their early memories? From a child’s story we expect not names and dates, but emotional truth and powerful atmosphere. And the fake memoirists can supply these because, most often, they actually did undergo some kind of serious war-related trauma. Kosinski really did spend his childhood in hiding from the Nazis in Poland; Rosenblat really did survive Buchenwald. Even Misha Defonseca lost her parents to the Nazis: they were Belgian Resistance fighters who were executed when she was a young child, after which she was raised by relatives. (Only Wilkomirski appears to have invented every aspect of his story—though even there, it has been suggested that his experiences as a wartime orphan formed the basis of his Holocaust “memories.”)