Lyn, you're right. La France is said to have been the first hybrid tea, and it is dated 1867. I'll edit my comments accordingly.
I do find 1836 and 1837 specified as the cut-off date for OGR's in a few sources. I wonder what they were using as the milestone event. Is it possible it has something to do with the hybrid perpetual class? Hybrid perpetuals are not classified as OGRs, but they were around before 1867. I know some were bred in the 1840s.