In Browning-Ferris Industries, Inc. v. Lieck, 881 S.W.2d 288, 293, 37 Tex. Sup. Ct. J. 851 (Tex. 1994) the Court held that a defendant satisfies malicious prosecution's causation requirement when he "procures" the criminal proceedings at issue. The Restatement's comment on procurement, quoted approvingly in Lieck, reveals the similarity between the causation standards of "procuring" a criminal proceeding and "instigating" an arrest. For a defendant to procure proceedings, "it must . . . appear that his desire to have the proceedings initiated, expressed by direction, request or pressure of any kind, was the determining factor in the official's decision to commence the prosecution . . . ." Thus, much like instigation of a false imprisonment, procurement of criminal proceedings requires a direction or request for the action taken. Also, much like the false imprisonment rule, merely reporting a crime and the suspected criminal to law enforcement authorities does not constitute procurement of criminal proceedings when the authorities exercise discretion in deciding whether to prosecute. See Lieck, 881 S.W.2d at 293. We held in Lieck, that a person reporting criminal conduct to the authorities may nevertheless be considered to have procured the proceedings if he "provides information which he knows is false." This exception to the rule was justified because a person "who provides false information cannot complain if a prosecutor acts on it; he cannot be heard to contend that the prosecutor should have known better. Such a person has procured the resulting prosecution, regardless of the actions of the prosecutor, and the causation element for malicious prosecution is satisfied." This reasoning applies with equal force in the false imprisonment context. A person who merely gives law enforcement authorities information may not have directed or requested a subsequent arrest. But when that person knowingly gives false information, he cannot complain if the law assumes that the subsequent arrest was made "to carry out his request." Such a person has instigated the arrest, and false imprisonment's causation requirement is satisfied.