Division V: Discovery and Inspection · Last amended January 1, 2015 · Last verified July 15, 2026
In one sentenceRule 1.509 lets any party serve written interrogatories on another party, caps them at 30 including subparts absent a stipulation or court leave, and requires specific objections, sworn answers, and service within 30 days.
a.Except in small claims, any party may serve written interrogatories to be answered by another party or, if the other party is a public or private corporation or a partnership or association or governmental agency, by any officer or agent, who shall furnish such information as is available to the party.
b.Each interrogatory, unless the court has ordered otherwise, must be provided in an electronic word processing format. An interrogatory that does not comply with this requirement shall be subject to objection.
c.Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath. The grounds for objecting to an interrogatory must be stated with specificity. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure. A party may answer an interrogatory in whole or in part subject to an objection without waiving that objection. Any answer so provided is subject to the duty to supplement set forth in rule 1.503 (4), but the party does not waive the objection by supplementing. Where an answer is provided subject to an objection, the answering party must specify the extent to which the requested information has not been provided.
d.A party answering interrogatories must set out each interrogatory immediately preceding the answer to it. A failure to comply with this rule shall be deemed a failure to answer and shall be subject to sanctions as provided in rule 1.517. Answers are to be signed by the person making them. Answers shall not be filed; however, they shall be served upon all adverse parties within 30 days after the interrogatories are served. Objections, if any, must be signed by the attorney who objects and must be served within 30 days after the interrogatories are served. The court may allow a shorter or longer time. The party submitting the interrogatories may move for an order under rule 1.517 (1) with respect to any objection to or other failure to answer an interrogatory.
e.Except as provided in rule 1.509 (4), or unless otherwise stipulated or ordered by the court for good cause shown, a party must not serve on any other party more than 30 interrogatories, including all discrete subparts. Any discrete subpart to a nonpattern interrogatory will be considered a separate interrogatory. A motion for leave of court to serve more than 30 interrogatories must be in writing and shall set forth the proposed interrogatories and the reasons establishing good cause for their use.
a.Interrogatories may relate to any matters which can be inquired into under rule 1.503, including a statement of the specific dollar amount of money damages claimed, the amounts claimed for separate items of damage, and the names and addresses of witnesses the party expects to call to testify at the trial. Interrogatory answers may be used to the extent permitted by the rules of evidence.
b.An interrogatory otherwise proper is not necessarily objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or the application of law to fact, but the court may order that such an interrogatory need not be answered until after designated discovery has been completed or until a pretrial conference or other later time.
(3)Option to produce business records. Where the answer to an interrogatory may be derived or ascertained from the business records, including electronically stored information, of the party upon whom the interrogatory has been served or from an examination, audit or inspection of such business records, or from a compilation, abstract or summary based thereon, and the burden of deriving or ascertaining the answer is substantially the same for the party serving the interrogatory as for the party served, it is a sufficient answer to such interrogatory to specify the records from which the answer may be derived or ascertained and to afford to the party serving the interrogatory reasonable opportunity to examine, audit or inspect such records and to make copies, compilations, abstracts or summaries. A specification shall be in sufficient detail to permit the party serving the interrogatory to locate and identify as readily as can the party served, the records from which the answer may be ascertained.
(4)Pattern interrogatories. The supreme court, by supervisory order or otherwise, may approve pattern interrogatories for different classes of cases. Any pattern interrogatory and its subparts are counted as one interrogatory.
Comment
Rule 1.509
(1)
(c). The rule mirrors Federal Rule of Civil Procedure 33(b)(3) and (4) in requiring that objections to interrogatories be specific and providing that any ground not raised in a timely objection is waived. The rule further allows a party to respond to an interrogatory subject to an objection without waiving that objection. In such cases, however, the responding party must clearly indicate whether any responsive information is being withheld subject to the objection.
[Court Order August 28, 2014, effective January 1, 2015]
Rule 1.509
(4). Parties are encouraged to use supreme court-approved pattern discovery when appropriate. A party may use one or more pattern interrogatories that are part of an approved set of pattern interrogatories. Any approved pattern interrogatory is counted as one interrogatory in determining the total number of permissible interrogatories, regardless of the number of subparts or multiple inquiries within the interrogatory. In contrast, each discrete subpart of a nonpattern interrogatory will count as a separate interrogatory. A party may combine pattern interrogatories with other interrogatories, subject to applicable limitations as to number. A party should not serve pattern interrogatories that have no application to the case.
[Court Order August 28, 2014, effective January 1, 2015]
The requirement to file answers or objections, absent court order, is eliminated. Notices of serving interrogatories are abolished. Rule 1.509(2) adds to the permissible scope of interrogatories the amounts claimed for items of damages approved by the court in Gordon v. Noel, 356 N.W. 2d 559 (Iowa 1984), and the addresses of trial witnesses.
Plain-English Summary
Rule 1.509 governs written interrogatories, the written-question-and-answer tool parties use to pin down facts before trial. Any party may serve interrogatories on another party (or, if that party is a corporation, partnership, association, or government agency, on an officer or agent who can supply the information available to it), except in small claims cases. Each interrogatory must be provided in an electronic word processing format unless the court orders otherwise, and one that is not can draw an objection on that ground alone.
Answering takes discipline. The responding party must set out each interrogatory immediately before its answer, answer separately and fully under oath, and state any objection with specificity — a ground left out of a timely objection is waived unless the court excuses the omission for good cause. A party can answer subject to an objection without giving up that objection, so long as it specifies what has been withheld; that answer still carries the ongoing duty to supplement under Rule 1.503(4). Answers are signed by the person who made them and served — not filed — within 30 days; objections are signed by the objecting attorney and served on the same 30-day clock, though the court can shorten or lengthen it. Treating a required interrogatory answer as though it were never given exposes a party to the sanctions in Rule 1.517.
The rule also caps the tool's reach: absent a stipulation or a written motion showing good cause, a party may not serve more than 30 interrogatories on any other party, counting every discrete subpart of a non-pattern interrogatory separately. Pattern interrogatories approved by the supreme court under Rule 1.509(4) count as one interrogatory regardless of how many subparts they carry, which is why the official Comment encourages using approved pattern sets where they fit the case. Scope reaches anything discoverable under Rule 1.503, including a specific dollar figure for damages, itemized amounts for separate damage categories, and the names and addresses of trial witnesses; an interrogatory calling for an opinion or a contention applying law to fact is not automatically objectionable, though the court can defer the answer until later in the case. Rule 1.509(3) offers a shortcut for record-heavy answers: if the answer can be derived from the responding party's business records and both sides would face roughly the same burden extracting it, pointing to the records in enough detail to let the requesting party locate them is a sufficient answer.
Frequently Asked Questions
How many interrogatories can I send to the other side in an Iowa case?
Rule 1.509(1)(e) caps the number at 30, counting every discrete subpart of a non-pattern interrogatory separately, unless the parties agree to more or the court grants leave on a written motion showing good cause. A supreme court-approved pattern interrogatory counts as one interrogatory no matter how many subparts it has.
What format do my interrogatories need to be in?
Rule 1.509(1)(b) requires interrogatories to be provided in an electronic word processing format unless the court orders otherwise. An interrogatory that does not comply can be objected to on that basis alone.
Can the other side answer an interrogatory and object to it at the same time?
Yes. Rule 1.509(1)(c) allows a party to answer in whole or in part subject to an objection without waiving that objection, so long as the answering party specifies how much of the requested information has not been provided.
How long does a party have to answer interrogatories?
Answers are served — not filed — within 30 days after the interrogatories are served, and objections follow the same 30-day deadline, though the court may shorten or lengthen that period.
Can I ask for a specific dollar amount of damages in an interrogatory?
Yes. Rule 1.509(2)(a) allows interrogatories to ask for the specific dollar amount of money damages claimed and the amounts claimed for separate items of damage, along with the names and addresses of trial witnesses.
Source & verification. Rule text and the Comment are
reproduced verbatim from the Iowa Rules of Civil Procedure, adopted by the
Iowa Supreme Court. Last verified July 15, 2026.
· Official source
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