What is the test for making an argument in reply brief for the first time?

^3. Wife argues for the first time in her reply brief that "[a]n order requiring [her] to buy a policy to which [Husband] would be a beneficiary violates Article 1 Section 1 of the California Constitution[.]" We will not entertain arguments raised for the first time in reply. (Varjabedian v. City of Madera (1977) 20 Cal.3d 285, 295, fn. 11 [for "[o]bvious reasons of fairness," declining to consider issue raised by appellant for first time in reply brief].)