1867 prevents a Senator from being elected as a Member of Parliament; similarly, s. 65(c) of the Canada Elections Act makes members of provincial or territorial legislatures ineligible to be candidates to the House of Commons. At the provincial level, the situation varies from one province to another. In most circumstances, an elected official almost always resigns their first post when elected to another. Dual representation has occurred occasionally when the member was elected to a second office shortly before their other term of office was due to expire anyway and whereby the short time frame would not merit the cost of a special by-election. In 1996, for example, Jenny Kwan continued to be a Vancouver city councillor after being elected to the provincial legislature. The British Columbia legislature had debated a "Dual Office Prohibition Act" which failed to pass second reading. In the first few years after Confederation in 1867, however, double mandates were common. In the first House of Commons, there were fifteen Members of Parliament from Quebec who simultaneously held seats in the Legislative Assembly of Quebec, including the Premier Pierre-Joseph-Olivier Chauveau. There were also four members of Parliament from Ontario who also held seats in the Legislative Assembly of Ontario, including the first two Premiers, John Sandfield Macdonald and Edward Blake. Other prominent federal politicians with double mandates included George-Étienne Cartier, Christopher Dunkin, Hector Langevin, the second Premier of British Columbia Amor de Cosmos, and two members from Manitoba, Donald Smith and Pierre Delorme. Another famous example is that of the de facto leader of the Liberals, George Brown, who ran for both federal and provincial seats in 1867. Brown lost both elections, and soon thereafter began campaigning for the prohibition of double mandates. The double mandate was prohibited from the start in Nova Scotia and New Brunswick; it was abolished in Ontario in 1872, in Manitoba in 1873, and in 1873 the federal parliament passed a law against it; Quebec passed its own law abolishing it in 1874. However, dual mandates within a province remained legal. From 1867 to 1985, 305 mayors were also members of the Quebec legislative assembly (MLA). The two best-known cases were those of S.N. Parent who was simultaneously mayor of Quebec City (1894-1906), MLA and Premier of Quebec (1900-1905). Longtime Montreal Mayor Camilien Houde (1928–32, 1938–40) was also simultaneously MLA for a total of 2 /1/2 years during his mandates