For these reasons, there was a reluctance to use the title. Although Walpole is now called the "first" prime minister, the title was not commonly used during his tenure. Walpole himself denied it. In 1741, during the attack that led to Walpole's downfall, Samuel Sandys declared that "According to our Constitution we can have no sole and prime minister". In his defence, Walpole said "I unequivocally deny that I am sole or Prime Minister and that to my influence and direction all the affairs of government must be attributed". George Grenville, Prime Minister in the 1760s, said it was "an odious title" and never used it. Lord North, the reluctant head of the King's Government during the American War of Independence, "would never suffer himself to be called Prime Minister, because it was an office unknown to the Constitution".