The Duke in Bavaria title was accorded in 16 February 1799, when the first duke's cousin of the same Birkenfeld branch, the future Bavarian king Maximilian Joseph, succeeded as Elector in both Bavaria and the Palatinate. According to Allemagne Dynastique, as best I can understand, the title change was partly done because in the same period territories that had been in the new duke's personal possession had become part of an enlarged France.
It might also have to do with the fact that the dukes in Bavaria were the only other line of the House of Wittelsbach and “consolidating” the entire house’s main territorial designation (albeit with different prepositions) was a consolation and for the betterment of the ducal branch.
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