 Indeed, when Lincoln's dismissal of Chief Justice Taney's ruling was criticized in a September 1861 editorial by Baltimore newspaper editor Frank Key Howard (Francis Scott Key's grandson), Howard was himself arrested by order of Lincoln's Secretary of State Seward and held without trial.Howard described these events in his 1863 book "Fourteen Months in American Bastiles", where he noted that he was imprisoned in Fort McHenry, the same fort where the Star Spangled Banner had been waving "o'er the land of the free" in his grandfather's song.Two of the publishers selling his book were then arrested.