Roger Curtis had been flag captain to Lord Howe at the Glorious First of June, and became closely associated with the perceived injustices in the distribution of awards in the aftermath of the battle. Curtis further infuriated some of his fellow officers by acting as prosecutor at the court-martial in which Anthony Molloy was criticised for his conduct during the Atlantic campaign of May 1794. Molloy was effectively forced out of the Navy and Roger Curtis attracted a significant amount of criticism, especially from Cuthbert Collingwood, who took a personal dislike to him.