Can an unlawful detainer action be consolidated with a separate fraud action?

Asuncion v. Superior Court, supra, 108 Cal.App.3d 141, 146, 166 Cal.Rptr. 306, held that, consistent with due process guarantees, homeowners cannot be evicted without being permitted to raise affirmative defenses which if proved would maintain their possession and ownership. The court suggested the use of certain existing procedural devices to facilitate accommodating an unlawful detainer action with a separately filed fraud action, such as a stay of the unlawful detainer proceedings until trial of the fraud action, or, in the alternative, consolidation of the actions. (Pp. 146-147, 166 Cal.Rptr. 306.)