In Becker v. S.P.V. Construction Co. (1980) 27 Cal.3d 489, the plaintiff's complaint sought damages "in excess of $ 20,000 . . . or according to proof," punitive damages of $ 100,000 and costs. Judgment by default was entered for $ 26,457.50 in compensatory damages and $ 2,500 in attorney fees and costs. ( Id. at pp. 491-492.) The Supreme Court held the judgment was invalid. It explained section 580 mandates that the relief granted to a plaintiff in a default judgment cannot exceed the amount demanded in the complaint. "The primary purpose of this section is to insure that defendants in cases which involve a default judgment have adequate notice of the judgments that may be taken against them.'" ( Id. at p. 493.) The Becker court rejected the plaintiff's argument that section 580 requires notice of the type of relief sought but does not restrict the award of damages to the specific amount stated in the complaint. It reasoned the notice requirement was "designed to insure fundamental fairness. Surely, this would be undermined if the door were opened to speculation, no matter how reasonable it might appear in a particular case, that a prayer for damages according to proof provided adequate notice of a defaulting defendant's potential liability. If no specific amount of damages is demanded, the prayer cannot insure adequate notice of the demands made upon the defendant. Consequently, a prayer for damages according to proof passes muster under section 580 only if a specific amount of damages is alleged in the body of the complaint." ( Id. at p. 494.) The Becker court ordered the trial court to modify the judgment by striking the award of damages in excess of $ 20,000 and any attorney fees (because no such fees were set forth in the complaint).