Pryor v. Pryor

In Pryor v. Pryor (2009) 177 Cal.App.4th 1448, the daughter of the late comedian Richard Pryor sought to posthumously annul his marriage under section 2210, subdivision (d), on the ground that Pryor's wife forged the marriage certificate and thus the marriage was procured by fraud. (Pryor, supra, 177 Cal.App.4th at p. 1452.) The trial court granted a motion to quash the petition on the ground that the daughter lacked standing, and the Court of Appeal affirmed. It observed that under section 2210, a fraudulent marriage is voidable, not void. (Pryor, at pp. 1454-1455.) It then noted that under section 2211, subdivision (d), the only party with standing to annul the marriage on the ground of fraud is the person who was defrauded. (Pryor, at p. 1455.)