Model factories - making relationships

example.php

<?php

$factory->define(App\User::class, function (Faker\Generator $faker) {
    static $password;

    return [
        'name' => $faker->name,
        'email' => $faker->unique()->safeEmail,
        'password' => $password ?: $password = bcrypt('secret'),
        'remember_token' => str_random(10),
        'example_id' => function (array $user) {
            return factory(App\Example::class)->create()->id;
        }
    ];
});

// Using the following, will cause Eloquent to persist the models to the database
$user = factory(App\User::class)->create();
// An 'Example' will also be created


// However, If I want to just 'make' the instance:
$user = factory(App\User::class)->make();
// An 'Example' will still be created, rather than made.

I suppose I could use states, where I override creating the relationship with a make, but that seems a bit of a code smell to me.

Actually, the way that model factories work is, they use arrays rather than objects. So, example_id expects an id, not an instance
If I'm making a model, it would not have an id and therefore the factory created model would have a value of null for example_id.