Sippel, Gregory Scott, WR-93,347-02

Gregory Scott Sippel pled guilty in July 2014 to two second-degree felony drug offenses in Harris County, Texas: intent to deliver hydrocodone (28-200 grams) and heroin (4-200 grams), receiving concurrent six-year sentences.
No laboratory testing of the substances had been performed at the time of Sippel's plea.
A month after the plea, lab results revealed no hydrocodone, only 0.44 grams of Alprazolam, and less than one gram of heroin; these results were not disclosed to Sippel until almost eight years later.
Sippel filed applications for habeas corpus in 2023, claiming his pleas were involuntary and that he was actually innocent based on the later-disclosed lab reports.
The Texas Court of Criminal Appeals majority granted relief, finding Sippel's pleas involuntary per Ex parte Mable, but Judge Yeary dissented, arguing the need for further fact-finding and challenging the standards set by Mable.

Issue	Sippel's Argument	State's Argument	Held (Majority/Yeary Dissent)
Was Sippel's plea involuntary due to later-provided exculpatory lab results?	Did not possess charged substances; plea was not knowing/voluntary	No evidence plea was coerced or counsel was ineffective	Majority: Yes; Yeary dissent: No
Is Sippel actually innocent given lab results showed different/lesser substances?	Lab showed he possessed neither hydrocodone nor 4+ grams of heroin	Not directly addressed; focuses on procedural grounds	Not expressly held; factual issues remain
Is post-conviction relief warranted based on due process and new factual findings?	Relief required as factual innocence is shown by new evidence	Relief improper absent proof of coercion, fraud, or ineffective counsel	Majority: Yes; Yeary: Needs further development
Should the court remand for further factual development before granting relief?	Court has enough (majority position)	Remand required to investigate charging and lab process history	Majority: No; Yeary: Yes

Ex parte Mable, 443 S.W.3d 129 (Tex. Crim. App. 2014) (voluntariness of plea may be retroactively undermined by subsequently revealed factual innocence)
Ex parte Broussard, 517 S.W.3d 814 (Tex. Crim. App. 2017) (mistaken substance identity does not automatically invalidate otherwise voluntary pleas)
Ex parte Saucedo, 576 S.W.3d 712 (Tex. Crim. App. 2019) (concurrence critiques retroactive plea involuntariness standard)
Ex parte Ohlemacher, 666 S.W.3d 528 (Tex. Crim. App. 2023) (newly discovered facts demonstrating actual innocence may entitle applicant to habeas relief)