that the clause defining the northern boundary depended on "a fact not yet ascertained" (the latitude of the southern extreme of Lake Michigan), and the members "thought it unnecessary to take it [the provision], at the time, into consideration." When Congress created the Michigan Territory in 1805, it used the Northwest Ordinance's language to define the territory's southern boundary, disregarding that provision in Ohio's state constitution. This difference, and its potential ramifications, apparently went unnoticed at the time, but it established the legal basis for the conflict that would erupt 30 years later. Creation of the Toledo Strip The location of the border was contested throughout the early 19th century. Residents of the Port of Miami—which would later become Toledo—urged the Ohio government to resolve the border issue. The Ohio legislature, in turn, passed repeated resolutions and requests asking Congress to take up the matter. In 1812, Congress approved a request for an official survey of the line. Delayed because of the War of 1812, it was only after Indiana's admission to the Union in 1816 that work on the survey commenced. At that time, the border between Michigan and Indiana was altered from the Northwest Ordinance boundary – over the protests of the Michigan Territory – moving it northward to give the new state substantial frontage on Lake Michigan. U.S. Surveyor General Edward Tiffin, who was in charge of the survey, was a former Ohio governor, and employed William Harris to survey not the Ordinance Line, but the line described in the Ohio Constitution of 1802. When completed, the "Harris Line" placed the mouth of the Maumee River completely in Ohio, as intended by the drafters of the state constitution. When the results of the survey were made public, Michigan territorial governor Lewis Cass objected, writing in a letter to Tiffin that the survey was biased to favor Ohio and "is only adding strength to the strong, and making the weak still weaker." In response, Michigan commissioned a second survey that was carried out by John A. Fulton. The Fulton survey was based upon the original 1787 Ordinance Line, and after measuring the line eastward from Lake Michigan to Lake Erie, it found the Ohio boundary to lie just southeast of the mouth of the Maumee River. The region between the Harris and Fulton survey lines formed what is now known as the "Toledo Strip". This ribbon of land