 Welch appealed to the Court of Appeals for the Eleventh Circuit, which ruled that the offense was a violent felony under the residual clause, but did not decide whether it qualified under the element clause.The Supreme Court denied certiorari in 2013, making the sentence final.Welch then entered a habeas corpus challenge, claiming that the strong arm robbery conviction, one of the three prior felonies, was impermissibly vague, which the District Court denied.