have given the liberal regime cash but also would have granted the United States perpetual military and economic rights on Mexican territory. The treaty failed to pass in the U.S. Senate, but the U.S. Navy nonetheless helped protect Juárez's government in Veracruz. Liberals thereafter accumulated victories on the battlefield until Conservative forces surrendered on December 22, 1860. Juárez returned to Mexico City on January 11, 1861 and held presidential elections in March. Although Conservative forces lost the war, guerrillas remained active in the countryside and would join the upcoming French intervention to help establish the Second Mexican Empire. Background After achieving independence in 1821, Mexico would alternatively find itself governed by both liberal and conservative coalitions. The original Constitution of 1824 established the federalist system championed by the liberals, with Mexican states holding sovereign power and the central government being weak. The brief liberal administration of Valentín Gómez Farías attempted to implement anti-clerical measures as early as 1833. The government closed church schools, assumed the right to make clerical appointments to the Catholic Church, and shut down monasteries. The ensuing backlash would result in Gómez Farías's government being overthrown and conservatives established a Centralist Republic in 1835 that lasted until the outbreak of the Mexican–American War in 1846. In 1854 there was a liberal revolt, known as the Plan of Ayutla against the dictatorship of Santa Anna. A coalition of liberals, including Benito Juárez, then governor of Oaxaca, and Melchor Ocampo of Michoacán overthrew Santa Anna, and the presidency passed on to the liberal caudillo Juan Alvarez. La Reforma [[File:Alegoría de la Constitución de 1857.jpg|right|thumbnail|Allegory of the Constitution of 1857, Petronilo Monroy, 1869.]] Juan Alvarez assumed power in November, 1855. His cabinet was radical and included the prominent liberals Benito Juárez, Miguel Lerdo de Tejada, Melchor Ocampo, and Guillermo Prieto, but also the more moderate Ignacio Comonfort. Clashes in the cabinet led to the resignation of the radical Ocampo, but the administration was still determined to pass significant reforms. On November 23, 1855, the Juárez Law, named after the Minister of Justice, substantially reduced the jurisdiction of military and ecclesiastical courts which existed for soldiers and clergy. Further dissension within liberal ranks led to Alvarez's resignation and the more moderate Comonfort becoming president on December 11, who chose a new cabinet. A constituent congress began meeting on February 14, 1856 and ratified the Juárez law. In June, another major controversy