In De Anza Santa Cruz Mobile Estates Homeowners Assn. v. De Anza Santa Cruz Mobile Estates (2001) 94 Cal.App.4th 890, the defendant mobilehome park owners challenged the jury's award of punitive damages based on their violation of Mobilehome Residency Law. ( Id. at p. 894.) The complaint filed by the homeowners association alleged intentional torts in addition to the statutory violation, but the tort claims were neither argued nor proven at trial. ( Id. at p. 904.) The court directed a verdict in favor of the homeowners association on the question of the statutory violation, and allowed the jury to decide whether the association was also entitled to punitive damages based on the statutory violation alone. (Ibid.) On appeal, the court addressed the question whether the park owners waived their challenge to punitive damages by submitting a proposed special verdict form authorizing the jury to make a finding of punitive damages. ( Id. at p. 907.) After reviewing the record, the court noted that the purpose of the proposed verdict form was to renew an earlier contention that the jury must determine actual damages before awarding punitive damages. It concluded the park owners did not invite any error. ( Id. at p. 908.)