In the first half of the 20th century, Douglas Southall Freeman kept criticism of Longstreet foremost in Civil War scholarship in his biography of Lee. "The battle was being decided at that very hour in the mind of Longstreet, who at his camp, a few miles away, was eating his heart away in sullen resentment that Lee had rejected his long cherished plan of a strategic offensive and a tactical defensive." He called Longstreet's performance on July 2 so sluggish that "it has often been asked why Lee did not arrest him for insubordination or order him before a court-martial". Historian Gary W. Gallagher notes that Freeman moderated his views in his later three-volume set, "Lee's Lieutenants: a Study in Command", where he states that Longstreet's "attitude was wrong but his instinct was correct. He should have obeyed orders, but the order should not have been given." Clifford Dowdey, a Virginia newspaperman and novelist, was noted for his severe criticism of Longstreet in the 1950s and 1960s.