In Prystash v. State. 3 S.W.3d 522 (Tex. Crim. App. 1999), cert. denied, 529 U.S. 1102, 120 S. Ct. 1840, 146 L. Ed. 2d 782 (2000) the defense asked the trial court not to submit the anti-parties special issue. Id. at 529-530. The Court held that the defendant was estopped from complaining on appeal about the absence of the issue - regardless of whether the issue was waivable. Id. at 531-532. The Court reasoned that a crucial distinction exists between the concepts of "waiver" and "invited error": "The question was not whether appellant could waive a right, it was whether he could complain of an action he requested." Id. at 531. The Court held that the definition of what can constitute error "excludes those actions of the trial court actually sought by the party to that tribunal." Id.