Texas Legal Glossary · Personal Injury

Interrogatories

Written and reviewed by Shane M. Boasberg, founder of SMB Law, PC · Licensed in Texas since 2003 · Updated October 2026

Definition: Interrogatories are written questions one party sends another in a Texas lawsuit under Rule of Civil Procedure 197, to be answered in writing under oath within 30 days. Most injury cases proceed under Level 2 discovery, which allows 25 interrogatories per side.

Also called: written interrogatories, rogs

What interrogatories mean in Texas

Interrogatories are formal written questions served by one party on another as part of discovery. Texas Rule of Civil Procedure 197 governs them. The responding party must answer each question separately, in writing, and must verify the answers under oath, except for answers about persons with knowledge, trial witnesses, and legal contentions, which the lawyer may sign. The deadline is 30 days after service.

Interrogatories go only to parties, never to witnesses. A plaintiff cannot send them to the defendant’s insurer or a bystander. They are the cheapest discovery tool available and are almost always the first thing served after a case is filed.

How it works in practice

The number is limited by the case’s discovery level under Rule 190. Most injury suits in Travis County district courts are Level 2 cases, which under Rule 190.3 allow each party 25 interrogatories, not counting those that ask only to identify or authenticate specific documents. Discrete subparts count as separate questions, so drafting matters. Level 1 expedited actions allow fewer, and Level 3 cases run on a court-ordered plan.

Typical defense interrogatories ask an injured plaintiff to list every doctor seen in the past ten years, every prior injury and claim, every employer, and every item of damages with the amount. Plaintiffs ask the defendant to describe how the crash happened, identify all insurance, and admit or deny the facts of fault. Contention interrogatories ask a party to state the factual basis for a legal position, and Rule 197.1 permits them, though a party is not required to marshal all of its evidence in response. Objections must be specific, and an evasive or incomplete answer is treated as a failure to answer.

Why it matters in your case

Interrogatory answers are sworn statements. They lock in your account of the crash, your injuries, and your medical history long before trial, and the defense will compare them word for word against your deposition and your records. An omitted prior injury reads to a jury as a lie, even when it was an honest oversight. We draft answers with the client, against the records, so the sworn version is the accurate one.

This entry explains Texas law in general terms and is not legal advice for any specific situation. Statutes and case law change; the date above reflects the last review.