discussed Cited as authority (rule) Travis A. v. Vilma B. (2×) also: Cited "see" However, proof that a defendant spouse induced the plaintiff spouse to marry with the sole objective of obtaining an immigration or citizenship benefit may, in certain cases, constitute grounds for an annulment ( see Brillis v Brillis , 4 NY2d 125, 127 [1958]; [*2] Avnery v Avnery , 50 AD2d at 808; Miodownik v Miodownik , 259 App Div 851, 851 [1940]; Bracksmayer v Bracksmayer , 22 NYS2d 110 , 111 [Sup Ct, NY County 1940]; compare Novick v Novick , 17 Misc 2d 350, 351 [Sup Ct, NY County 1959]).

discussed Cited as authority (rule) Campbell v. Thomas In cases of fraud or temporary incapacity, even where the surviving spouse has engaged in wrongdoing, it is possible for the deceased spouse to ratify, or condone, the marriage at any time before his or her death (see Domestic Relations Law § 140 [e] [“a marriage shall not be annulled ... on the ground of fraud, if it appears that, at any time before the commencement thereof, the parties voluntarily cohabited as husband and wife, with a full knowledge of the facts constituting the fraud”]; Domestic Relations Law § 140 [c] [action to annul marriage on mental illness grounds may be “main…