Lamberti v. Lamberti (1969) 272 Cal. App. 2d 482 involved a man who was in the United States as a visitor. To avoid deportation, he married a United States citizen in a civil ceremony. (Id. at p. 483.) The parties agreed that they would also marry in a religious ceremony about three months later. (Id. at pp. 483-484.) Since his immigration problems were resolved, the husband refused to complete the religious ceremony, and the marriage was never consummated. (Id. at p. 484.) The trial court granted the annulment petition and the husband appealed. (Lamberti v. Lamberti, supra, 272 Cal. App. 2d 482, 484-485.) The appellate court said: "In order to determine what constitutes sufficient fraud to annul a marriage there must be regard for the whole status of both parties and the circumstances which induced the contract in short, the fraud must be determined by the circumstances of each case. We think it necessarily follows that an annulment of an unconsummated marriage may be secured more readily than one in a situation where the parties have cohabited as husband and wife." (Id. at p. 485.) The court held that an annulment was proper "where one prospective spouse, in order to induce the other to enter into a civil marriage, makes a promise of a subsequent religious ceremony without intending to keep it . . . ." (Ibid.) The appellate court therefore found substantial evidence to support the granting of the annulment.