From 1660 to 1763, Michigan was part of the Royal Province of New France, which included France's laws making sodomy a capital offense. In 1763, Michigan was transferred to Great Britain's Indian Reserve and adopted British buggery statute that mandated a sentence of death for male-male buggery. The Quebec Act of 1774 incorporated Michigan into the Province of Quebec. When Quebec split into Lower and Upper Canada in 1791, Michigan was part of Kent County, Upper Canada. In 1796, under terms negotiated in the 1794 Jay Treaty, Britain withdrew from Michigan and it was adopted into the Northwest Territory. The Northwest Territory had adopted a statute in 1795 that received all of the common law of England as well as all English statutes adopted prior to the English settlement of North America