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 Constable's later visits to Scotland are more fully recorded in the state papers of the period, and have in part been noted by his biographers. In December, 1595, the Earl of Errol gave a book to the King, at which the King was offended, and which Quin, an Irish poet in the court, ascribed to Constable. Colville refers to it as a seditious book in favor of Spain. In March, 1599, Constable himself arrived in Scotland and offered his services to the King, but was refused an audience and forced to account for himself before the Lords of the Session. Later he is described as an agent of the Pope accompanying the Lord of Boniton, and on September 22 about to return to France. In April, 1600, he sent the King news from Aragon, apparently as his paid correspondent, and in July of the same year a book which he had written, but which at this late date could hardly have been, as Mr. Sidney Lee infers, a copy of Diana. After the death of Elizabeth he ventured to return from the Continent to England, and April 28, 1604, was "a few days ago imprisoned" for writing to the Papal Nuncio in France stating that "the King had no religion at all and that everything he did was governed by political expediency." In August following, the Venetian Secretary wrote that Constable had been released from the Tower and confined to his own house. Little is known of his career from this time until his death abroad in 1613.

Both Constable and Montgomerie contributed laudatory sonnets to the first editions of the King's poems, the former to the Exercises at vacant houres of 1591, and the latter to the Essayes of a Prentise. Other more or less literary figures who enjoyed the King's favor were permitted similar