Can California Law Require Document Support for Interrogatory Responses?

Question from Bey, Can California Law Require Document Support for Interrogatory Responses?

Answer from AI:

Interrogatories and the Right to Obtain Supporting Documents

In California civil cases, interrogatories are written questions that one party serves on the other to obtain factual information. The responding party must answer each interrogatory under oath and, when appropriate, provide the documents that back up those answers. This requirement is found in the California Code of Civil Procedure (CCP).

Governing Statutes

• CCP § 2030.210‑§ 2030.240 – Sets the basic rules for serving and answering interrogatories.
• CCP § 2030.220 – Allows a party to demand that the responding party produce “any documents, tangible things, or other evidence” that support the answer.
• CCP § 2031.010‑§ 2031.310 – Governs the inspection, copying, and production of documents and tangible things in response to a request for production.

Together, these sections make it clear that a party may lawfully request the documents that underlie an interrogatory answer, provided the request is reasonably specific and relevant to the issues in the case.

How the Request Must Be Made

1. Identify the Interrogatory – Reference the exact interrogatory number and wording.
2. Specify the Documents – Describe the type of documents, date range, and any other detail that narrows the request (e.g., “all invoices dated Jan. 1‑Dec. 31 2023 supporting the answer to Interrogatory No. 5”).
3. Serve Within the Time Limits – The request must be served with the answer or within the time allowed for a supplemental response (generally 30 days after service of the interrogatories).

If the request is overly broad, the responding party may object on grounds of relevance, undue burden, or privilege. The court can then resolve any dispute.

Relevant Case Law

• Hanson v. City of Monterey (1976) 56 Cal.App.3d 925 – Reaffirmed that discovery includes “any matter, not privileged, that is relevant to the subject matter of the action.”
• Miller v. Superior Court (1995) 10 Cal.4th 1095 – Held that a party may compel production of documents that substantiate interrogatory answers, and that failure to do so can result in sanctions.

These cases illustrate that California courts view the production of supporting documents as an integral part of the discovery process.

Practical Tips

• Be Precise – Vague requests are more likely to be challenged.
• Limit Scope – Tailor the request to the issues in the case; avoid fishing expeditions.
• Document Privilege Claims – If a document is withheld on privilege grounds, the responding party must provide a privilege log.
• Consider Meet‑and‑Confer – Before filing a motion to compel, parties are required to meet and attempt to resolve the dispute informally (CCP § 2016.040).

When to Seek Professional Guidance

While the statutes and case law provide a clear framework, the specifics of each case—such as the relevance of particular documents or the applicability of privilege—can be complex. Consulting a licensed California attorney is advisable to:

• Draft precise interrogatory and document requests.
• Evaluate objections and privilege claims.
• Navigate motions to compel or protective orders.

Further Resources

• The California Courts’ discovery guide offers a practical overview of interrogatories and document production: California Courts – Discovery Overview.
• The full text of the California Code of Civil Procedure is available at the state’s legislative information site: California Code of Civil Procedure §§ 2030‑2031.

Under California law, therefore, it is permissible—and often required—to request the documents that support a party’s answers to interrogatories, as long as the request complies with the procedural rules and relevance standards set out in the CCP and relevant case law.