ran for reelection in 1856, however, his bilingual opponent Miguel A. Otero, contested the election results. Otero claimed Gallegos' inability to speak English disqualified him. Gallego made an impassioned self-defense in Spanish on the House floor, where he protested the "disappointment" he felt from the "sneers" of his colleagues. Nevertheless, Otero's bid was successful, and he replaced Gallego as the territorial representative of New Mexico. California's first U.S. senator, John C. Frémont, introduced legislation for the federal government to arbitrate land claim settlements. After the removal of Article X from the Treaty of Guadalupe Hidalgo, treaty citizens were stripped of any formal protection of their land rights. After gold was discovered at Sutter's Mill in Coloma, California in 1848, a massive migration flooded the state, sparking the Gold Rush. By 1852, the population of California had grown from 8,000 in 1848 to 260,000. These gold miners were largely landless and asserted ownership over California lands. The California Land Act of 1851, also known as the Gwin Act, after California senator William M. Gwin, created a Presidentially-appointed commission to settle disputed claims between the landholders and Anglo miners. Land In California's post-war years, land proved to be the most contentious and sought-after commodity. The California Land Act of 1851 established a commission to determine the validity of Spanish and Mexican land grants. In order to prove ownership over the property, landowners needed to both provide evidence of the initial grant, as well as submit proof they had made "structural and pastoral" improvements to the land. If they could not, Anglo squatters were free to claim ownership if they had "improved the land", a contentious claim which was often difficult to disprove. Additionally, because many of the initial Spanish and Mexican diseños" grants were vague, merely describing the natural boundaries of the property, contestations over the boundaries of ranchos were difficult for the Californios to prove. All documents submitted in support of a claim also needed to be translated into English. Some firms, like Halleck, Peachy & Billings, gained popular reputations as "friends to the Mexicans" for helping the Californios navigate the new American court system, but most land lawyers used the situation to their advantage, drawing out the cases and charging exorbitant fees for their services. In most instances, land claim cases often proved simply too expensive for most Californios to litigate. While the majority of cases were ultimately ruled in