In 1953, Ruby Elaine Naim, a white woman, wanted to have her marriage to Ham Say Naim, a Chinese man, declared invalid. Ruby Naim received an annulment in Virginia since her marriage violated the state’s 1924 Racial Purity Act. Ham Say Naim, however, challenged the nullification of his marriage, claiming Virginia’s ban against interracial marriages was unconstitutional.

In Naim v. Naim, the Virginia Supreme Court upheld the Racial Purity Act within the context of the 10th Amendment’s protection of states’ rights. This court declared the state could regulate interracial marriages in order to avoid “the corruption of blood” and ultimately a “mongrel breed of citizens.” The U.S. Supreme Court refused to hear Ham Say Naim’s appeal.