In common law, a marriage between persons of the same-sex was void "ab initio". In 1680, Arabella Hunt married "James Howard"; in 1682 the marriage was annulled on the ground that Howard was in fact Amy Poulter, a 'perfect woman in all her parts', and two women could not validly marry. In 1866, in "Hyde v. Hyde and Woodmansee" (a case of polygamy), Lord Penzance's judgment began "Marriage as understood in Christendom is the voluntary union for life of one man and one woman, to the exclusion of all others."