In In re Marriage of Mathews (2005) 133 Cal.App.4th 624, the wife had quitclaimed her interest in the couple's residence to the husband, in order to obtain a more favorable interest rate on a mortgage. Throughout the marriage, both parties believed the residence was community property and, after separation, discovered title was in the husband's name alone. The trial court declined to apply a presumption of undue influence, and determined the wife entered into the transaction freely, voluntarily and with a full understanding of the quitclaim deed. The Court of Appeal concluded that the trial court "improperly refused to apply the Family Code section 721 presumption of undue influence" and that the husband had the burden of overcoming the presumption of undue influence. ( Mathews, supra, 133 Cal.App.4th at p. 630.) However, the trial court had "concluded that the quitclaim deed was the voluntary and deliberate act of the wife, taken with full knowledge of its legal effect, and the husband did not unduly influence the wife to acquire title to the residence in his name alone." ( Id. at p. 632.) Because the question whether the presumption of undue influence was overcome is a question for the trier of fact, and because substantial evidence supported the trial court's conclusion, the Court of Appeal affirmed the judgment: "Substantial evidence supports the conclusion that Husband rebutted the presumption of undue influence over Wife's signing the quitclaim deed by a preponderance of the evidence." (Mathews, supra, 133 Cal.App.4th at p. 632.)