At least the latter two are certainly rarer."[12] An alternate expression of the idea comes from Jane West, in her 1812 novel The Loyalists: An Historical Novel:[11] "Let us not attribute to malice and cruelty what may be referred to less criminal motives."[13]: 134 A similar quote is also misattributed to Napoleon.[11] Andrew Roberts, in his biography of Winston Churchill, quotes from Churchill's correspondence with King George VI in February 1943 regarding disagreements with Charles De Gaulle: "'His 'insolence ... may be founded on stupidity rather than malice.'"[14]: 771