On March 22, 1794, Congress passed the Slave Trade Act of 1794, which prohibited making, loading, outfitting, equipping, or dispatching of any ship to be used in the trade of slaves, essentially limiting the trade to foreign ships. On August 5, 1797, John Brown of Providence, Rhode Island, became the first American to be tried in federal court under the 1794 law. Brown was convicted and was forced to forfeit his ship . In the 1798 act creating the Mississippi Territory, Congress allowed slaves to be imported from the rest of the United States to Mississippi Territory, and exempted the territory from the part of the 1787 Northwest Ordinance that abolished slavery in the Northwest Territory (modern-day Midwest) after 1800. However, the same act also abolished the importation of slaves to the Mississippi Territory from "foreign parts" (foreign nations). The penalty for illegally importing slaves from abroad to the territory was a fine of $300. In the Slave Trade Act of 1800, Congress outlawed U.S. citizens' investment in the trade, and the employment of U.S. citizens on foreign vessels involved in the trade.