Does a defendant have a right to appeal against a punitive damages award?

Civil Code section 3295, subdivision (d) requires a court to bifurcate the trial of the amount of the punitive damage award from the remainder of the trial upon application of the defendant; the same trier of fact must determine the amount of punitive damages as determined liability and the existence of "malice, oppression, or fraud." Although a defendant has a statutory right to have the same jury which determined liability determine punitive damages, a defendant may impliedly waive this statutory right by failing to timely object to a different procedure. (Medo v. Superior Court (1988) 205 Cal.App.3d 64, 69-70, 251 Cal.Rptr. 924.)