In Campbell v. McClure (1986) 182 Cal. App. 3d 806, a case involving punitive damages, the Court of Appeal for the Fourth Appellate District, Division One, noted that the record did not reflect any evidence of the defendant's wealth, an essential element of an exemplary damages claim. The court nevertheless concluded: "McClure's failure to raise the matter in the trial court precludes our consideration of the issue. " (Ibid.) In a footnote the court noted only the amount, and not the legality, of the damage award was at issue. ( Id. at p. 808, fn. 1.)