Does the doctrine of invited error apply to defense counsel?

" 'The doctrine of invited error is designed to prevent an accused from gaining a reversal on appeal because of an error made by the trial court at his behest. If defense counsel intentionally caused the trial court to err, the appellant cannot be heard to complain on appeal.' [Citation.] For the doctrine to apply, 'it must be clear from the record that defense counsel made an express objection to the relevant instructions. In addition, because important rights of the accused are at stake, it also must be clear that counsel acted for tactical reasons and not out of ignorance or mistake.' [Citation.] However, '[the] existence of some conceivable tactical purpose will not support a finding that defense counsel invited an error in instructions. The record must reflect that counsel

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had a deliberate tactical purpose.' [Citation.]" (People v. Bunyard (1988) 45 Cal.3d 1189, 1234.)