Rule 197.Interrogatories to Parties
Last amended September 1, 2023 · Last verified June 28, 2026
Full Text of Rule 197
Notes and Comments
Comment to 1999 change: 1. Interrogatories about specific legal or factual assertions – such as, whether a party claims a breach of implied warranty, or when a party contends that limitations began to run – are proper, but interrogatories that ask a party to state all legal and factual assertions are improper. As with requests for disclosure, interrogatories may be used to ascertain basic legal and factual claims and defenses but may not be used to force a party to marshal evidence. Use of the answers to such interrogatories is limited, just as the use of similar disclosures under Rule 194.6 is. 2. Rule 191’s requirement that a party’s attorney sign all discovery responses and objections applies to interrogatory responses and objections. In addition, the responding party must sign some interrogatory answers under oath, as specified by the rule. Answers in amended and supplemental responses must be signed by the party under oath only if the original answers were required to be signed under oath. The failure to sign or verify answers is only a formal defect that does not otherwise impair the answers unless the party refuses to sign or verify the answers after the defect is pointed out.
Plain-English Summary
Rule 197 covers interrogatories — written questions one party serves on another. They must be served no later than 30 days before the end of the discovery period, and the number a party may ask is set by the case's Rule 190 discovery level. They can reach any matter within the scope of discovery except expert matters, which Rule 195 governs, and they may ask a party to state its legal and factual contentions — but not to marshal all of its proof.
The responding party generally has 30 days to answer, with 50 days for a family-law defendant served before its answer is due. The party must sign the answers under oath, with limited exceptions, and may answer by pointing to business records when the burden of finding the answer is the same for both sides.
Frequently Asked Questions
How many interrogatories can you serve in Texas?
It depends on the discovery level set by Rule 190 — for example, 15 in Level 1 and 25 in Level 2. Each discrete subpart counts as a separate interrogatory.
Do interrogatory answers have to be signed under oath in Texas?
Yes. The responding party — not just the attorney — must sign the answers under oath, except for answers about persons with knowledge, trial witnesses, and legal contentions.