Tony A. Carwise confessed to and was convicted of conspiracy to commit armed robbery. His conviction was reversed on appeal due to the government's failure to establish by evidence independent of the confession that the crime of conspiracy had occurred. In its decision reversing Carwise's conviction, the Fifth District Court of Appeal certified a question to the Supreme Court. It asked whether Florida courts should retain the current standard for corroborating confessions or employ the more flexible standard utilized by federal courts.