In Fuller v. State, 829 S.W.2d 191, 201-02 (Tex.Cr.App. 1992), the defendant complained of the admission of a tape seized from a third person into evidence. The defendant argued that it was error to admit the tape recording into evidence because the defendant had made the tape and given it to another inmate, a Ms. Hall. A third inmate stole the tape from Ms. Hall and turned it over to the jail authorities. The defendant claimed that the tape was illegally obtained by the state and excludable under Article 38.23. This Court concluded that the defendant lacked standing to complain of the seizure of the videotape. In Fuller, this Court relied on the "fundamental rule of law that only the person whose primary legal right has been breached may seek redress for an injury. Standing must consist of some interest peculiar to the person individually and not as a member of the general public." Fuller, 829 S.W.2d at 201 (citing Hunt v. Bass, 664 S.W.2d 323, 324 (Tex. 1984) and Nobles v. Marcus, 533 S.W.2d 923, 927 (Tex. 1976)). Because the tape was not seized from the defendant, the "justiciable injury suffered as a direct and immediate result" of the taking of the tape was not the defendant's injury. The victim of the injury, if any, was Brenda Hall. This Court concluded that the defendant was "without standing to challenge such illegality in the context of a criminal prosecution." Fuller, 829 S.W.2d at 202. The Court did not follow the "plain" language of Article 38.23(a) on the issue of a defendant's standing to complain about a private person illegally seizing evidence from a third party. In Fuller v. State, 829 S.W.2d 191, 200 (Tex. Crim. App. 1992), cert. denied, 508 U.S. 941, 124 L. Ed. 2d 640, 113 S. Ct. 2418 (1993), the venireperson was challenged for cause on the ground that she would consider imposing capital punishment for serial murderers only. The Court said that "because our law does not categorically reserve capital punishment only for those who have murdered before, neither may individual jurors in a capital murder case. " We accordingly held that under these circumstances, the trial court did not abuse its discretion in granting the State's challenge for cause. Id. at 201.