Psychological research has discovered that episodic memories are constructive in nature. This paper examines how, despite being constructive, episodic memories can provide us with justification for beliefs about the past. In current literature, two major approaches to memorial justification are internalist foundationalism and reliabilism. I first demonstrate that an influential version of internalist foundationalism, dogmatism, encounters problems when we compare certain types of memory construction with cognitive penetration in perception. On the other hand, various versions of reliabilism all face skeptical (...) challenges. I propose an alternative, two-factor theory that recognizes an epistemic distinction typically overlooked by dogmatism and reliabilism. Although our account leaves certain aspects unspecified, it is an important step forward. (shrink)