in pre-Revolutionary times, customary dower accruing by operation of law is yet recognized in the law of the former French province of Quebec. The civil death which by English law seems to have applied to men only, might be by the French law incurred by women taking perpetual religious vows. Therefore, a widow entering into religion would lose her dower, although in some regions she was allowed to retain a moderate income. And now by the law of Quebec a widow joining certain religious orders of the province is deemed civilly dead and undoubtedly would suffer loss of dower. United States It was the law of dower unimpaired by statute which, according to the American commentator Chancellor Kent, has been "with some modifications everywhere adopted as part of the municipal jurisprudence of the United States". In American law, a widow's dower estate has phases: inchoate dower while the husband is still alive (wives co-sign their husbands' deeds for land in order to release their inchoate dower rights), unassigned dower after his death and before a dower lot is assigned to her, assigned (and if necessary admeasured) dower once the lot is determined. Then she can live on the dower lot or get its usufruct ("fruits" like actual fruit or animals grown there, and any rental income from her share), during her life. She can sell her unassigned or assigned dower rights, but could not sell them while they were still inchoate before her husband's death. Her dower lot is assigned to her by the husband's heirs who inherit the land, and it should be one-third of the husband's real property (by value, not by land area). If the widow disputes it, she or the heirs may file an action in court for admeasurment of dower and the court will determine and assign a dower lot to the widow. See Scribner on Dower. A widow's dower and widower's curtesy rights have been abolished by statute in most American states and territories, most recently in Michigan in 2016. Dower was never "received" into Louisianan law, its civil code being based mainly on French law. In Arkansas, Kentucky, Ohio and the Territory of Palmyra Island, a widow's dower remains a valid estate in land—modified and augmented in Arkansas and Kentucky with other protections for surviving spouses like elective share and community property. Relationship to religious profession During the pre-Reformation period, a man who