Because in 1956 The United States Supreme Court upheld Virginia's anti-miscegenation law by refusing to accept a challenge to it in Naim v. Naim, the Virginia Supreme Court of Appeals could not rule that the law was a violation of the U.S. Constitution since lower courts are not allowed to overrule the United States Supreme Court. Justice Carrico's opinion merely reiterates the arguments used in "Pace versus the State of Alabama" (1883) and "Plessy versus Ferguson" (1896) two United States Supreme Court decisions that had not been overturned prior to 1966, although "Brown v The Board of Education Of Topeka, Kansas" (1954) seemed to signal an end to the "separate but equal" doctrine established by the Supreme in Plessy. Many view Carrico's opinion upholding Virginia's segregationist and unconstitutional statute as obstructionist but it has not been established that Carrico, as a white jurist, arrived at his conclusions out of racial animosity towards African-Americans. Nevertheless, for many, the implication of racism from Carrico's opinion is hard to avoid given what appears to be his deliberate refusal to follow Supreme Court precedent, and indeed, Carrico's opinion was promptly and unanimously overruled by the United States Supreme Court.