For unknown reasons, Surveyor General Tiffin ordered the two surveys to close on the Northwest Ordinance (Fulton) line, rather than Harris' line, perhaps lending implicit support to Michigan's claims over Ohio's. Thus, townships that were established north of the line assumed they were part of the Michigan Territory. By the early 1820s, the growing territory reached the minimum population threshold of 60,000 to qualify for statehood. When Michigan sought to hold a state constitutional convention in 1833, Congress rejected the request because of the still-disputed Toledo Strip. Ohio asserted that the boundary was firmly established in its constitution and thus Michigan's citizens were simply intruders; the state government refused to negotiate the issue with the Michigan Territory. The Ohio Congressional delegation was active in blocking Michigan from attaining statehood, lobbying other states to vote against Michigan. In January 1835, frustrated by the political stalemate, Michigan's acting territorial Governor Stevens T. Mason called for a constitutional convention to be held in May of that year despite Congress' refusal to approve an enabling act authorizing such a state constitution. In February 1835, Ohio passed legislation that set up county governments in the Strip. The county in which Toledo sat would, later in 1835, be named after incumbent Governor Robert Lucas, a move that further exacerbated the growing tensions with Michigan. Also, during this period, Ohio attempted to use its power in Congress to revive a previously rejected boundary bill that would formally set the state border to be the Harris Line. Michigan, led by the young and hot-headed Mason, responded with the passage of the Pains and Penalties Act just six days after Lucas County was formed; the act made it a criminal offense for Ohioans to carry out governmental actions in the Strip, under penalty of a fine up to $1,000, up to five years imprisonment at hard labor, or both. Acting as commander-in-chief of the territory, Mason appointed Brigadier General Joseph W. Brown of the Third U.S. Brigade to head the state militia, with the instructions to be ready to act against Ohio trespassers. Lucas obtained legislative approval for a militia of his own, and he soon sent forces to the Strip area. The Toledo War had begun. Former United States President John Quincy Adams, who at the time represented Massachusetts in Congress, backed Michigan's claim. In 1833, when Congress rejected Michigan's request for a convention, Adams summed up his opinion on the dispute: "Never in the course of my life have I known a controversy of which all the right was so clearly on one side and all the power so overwhelmingly on the other."