On July 13, 1787, the Second Continental Congress passed the Northwest Ordinance, creating the Northwest Territory which included Michigan. In 1805, the U.S. Congress created the Michigan Territory, with Detroit as its territorial capital. Michigan first applied for statehood as early as 1832, though it was rebuffed due to a dispute with Ohio over the Toledo Strip, a 468-square mile (1,210 km²) area that included the important port city of Toledo. By 1835, Michigan had formed a state government without receiving authorization from Congress to do so. The state's boundaries included the contested area.