There was no doubt that Clement VII would like to do a favor for his great English champion, but two difficulties at once presented themselves. It would be a most dangerous precedent for the pope to reverse the decision of one of his predecessors. Worse still, the Emperor Charles V, the nephew of Queen Catherine, took up cudgels in his aunt's behalf and threatened Clement with dire penalties if he nullified the marriage. The pope complained truthfully that he was between the anvil and the hammer. There was little for him to do except to temporize and to delay decision as long as possible. The protracted delay was very irritating to the impulsive English king, who was now really in love with Anne Boleyn. Gradually Henry's former effusive loyalty to the Roman See gave way to a settled conviction of the tyranny of the papal power, and there rushed to his mind the recollection of efforts of earlier English rulers to restrict that power. A few salutary enactments against the Church might compel a favorable decision from the pope. Henry VIII seriously opened his campaign against the Roman Church in 1531, when he frightened the English clergy into paying a fine of over half a million dollars for violating an obsolete statute that had forbidden reception of papal legates without royal sanction, and in the same year he forced the clergy to recognize himself as supreme head of the Church "as far as that is permitted by the law of Christ." His subservient Parliament then empowered him to stop the payment of annates and to appoint the bishops without recourse to the papacy. Without waiting longer for the papal decision, he had Cranmer, one of his own creatures, whom he had just named archbishop of Canterbury, declare his marriage with Catherine null and void and his union with Anne Boleyn canonical and legal. Pope Clement VII thereupon handed down his long-delayed decision favorable to Queen Catherine, and excommunicated Henry VIII for adultery. [Sidenote: Separation of England from the Roman Catholic Church: the Act of Supremacy] The formal breach between England and Rome occurred in 1534. Parliament passed a series of laws, one of which declared the king to be the "only supreme head in earth of the Church of England," and others cut off all communication with the pope and inflicted the penalty of treason upon any one who should deny the king's ecclesiastical supremacy.