This work takes a historical approach to discussing Brown's ( 1958 ) paper, "Some Tests of the Decay Theory of Immediate Memory". This work was and continues to be extremely influential in the field of forgetting over the short term. Its primary importance is in establishing a theoretical basis to consider a process of fundamental importance: memory decay. Brown ( 1958 ) established that time-based explanations of forgetting can account for both memory capacity and forgetting of information over short periods of time. We discuss this view both in the context of the intellectual climate at the time of the paper's publication and in the context of the modern intellectual climate. The overarching theme we observe is that decay is as controversial now as it was in the 1950s and 1960s.