In In re Marriage of Liu (1987) 197 Cal. App. 3d 143, the husband testified that they were married in civil and traditional ceremonies in Taiwan. (Id. at p. 147.) The husband returned to the United States, and the wife asked him to apply for a green card so she could enter and remain in the United States. (Id. at pp. 147-148.) He did so, but the parties separated within a month and a half after the wife came to the United States. (Id. at p. 148.) The husband testified that he never had sexual relations with his wife. (Ibid.) "The trial court found that the marriage was never consummated, that the wife entered into the marriage for the purpose of obtaining a 'green card,' that she did not intend to engage in sexual relations or to perform her marital duties, and that the parties never cohabited as husband and wife. Consequently, the court found that the husband's consent to marry was obtained by fraud within the meaning of former Civil Code section 4425, subdivision (d)." (In re Marriage of Liu, supra, 197 Cal. App. 3d 143, 148, ) The appellate court found substantial evidence supporting the trial court's decision. It said: "An annulment may be had for fraud where a wife harbors a secret intention at the time of the marriage not to engage in sexual relations with her husband. " (In re Marriage of Liu, supra, 197 Cal. App. 3d 143, 156.) The court found that the annulment was properly granted because the wife did not intend to engage in sexual relations or to meet her marital duties. (Id. at p. 155.) It found substantial evidence to support this conclusion: (1) husband testified he never had sexual relations with his wife; (2) there was evidence of the wife's ulterior motive, i.e., to obtain a green card to allow her to reside in the United States; and (3) the marriage deteriorated rapidly as soon as the wife arrived in the United States. (Id. at p. 156.) Since there was substantial evidence to support the trial court's fraud finding, the finding was upheld. (Ibid.)