"In this circular dated March 19, 1866, the assistant commissioner for Virginia, Col. Orlando Brown, ordered his subordinates to register the names of freedmen who were "cohabiting together as man and wife" and to "take pains to explain to colored persons . . . that they [were] firmly married by the operation of the law." As the basis for his order, Brown cited two February 27, 1866, acts of the Virginia General Assembly that made provisions for issuing marriage licenses and the registration and legalization of marriage relations entered into by former slaves."