Before "Loving v. Virginia", there had been several cases on the subject of interracial sexual relations. Within the state of Virginia, on October 3, 1878, in "Kinney v. The Commonwealth", the Supreme Court of Virginia ruled that the marriage legalized in Washington, D.C. between Andrew Kinney, a black man, and Mahala Miller, a white woman, was "invalid" in Virginia. In the national case of "Pace v. Alabama" (1883), the Supreme Court of the United States ruled that the conviction of an Alabama couple for interracial sex, affirmed on appeal by the Alabama Supreme Court, did not violate the Fourteenth Amendment. Interracial marital sex was deemed a felony, whereas extramarital sex ("adultery or fornication") was only a misdemeanor.