## Facts

- Liguria Foods, Inc., an Iowa manufacturer of pepperoni and dried sausage products, sued Griffith Laboratories, Inc., a supplier of seasoning used in Liguria’s pepperoni.
- Liguria alleged the seasoning caused premature rancidity and economic losses, asserting implied-warranty claims; Griffith denied liability and blamed Liguria’s manufacturing practices.
- During discovery, both parties served interrogatory and document-production responses containing numerous generalized, stock objections (e.g., relevance, overbreadth, burden, privilege) without request-specific explanations.
- The court reviewed the written discovery responses and found the objections potentially obstructive and inconsistent with federal discovery requirements.
- The court issued an order to show cause requiring counsel who signed the discovery responses to appear and explain why sanctions should not be imposed for discovery abuses.
- The opinion resolved only the discovery-abuse/sanctions question, not the underlying warranty claims.

## Issues

1. Whether the parties’ generalized “boilerplate” objections to interrogatories and document requests complied with Federal Rules of Civil Procedure 26, 33, and 34.
2. Whether the use of such objections warranted sanctions against counsel or the parties.

## Decision

- The court held that both sides’ boilerplate objections were improper and violated the specificity requirements of Rules 33 and 34.
- The court found many objections merely recited legal labels (e.g., “overly broad,” “unduly burdensome,” “irrelevant,” “privileged”) without explaining the defect or the harm from responding.
- The court emphasized that Rule 33(b)(4) requires interrogatory objections to be stated with specificity.
- The court emphasized that Rule 34(b)(2)(B)–(C) requires specific objections and disclosure whether responsive materials are being withheld based on an objection.
- Despite finding violations, the court declined to impose sanctions, citing counsel’s professionalism, cooperation in resolving disputes, candid acknowledgment of improper practices, and stated commitments to change future conduct.
- The court warned that continued use of boilerplate objections could lead to sanctions in future cases.

## Legal Principles

- Discovery objections must be request-specific; generic, omnibus objections that merely list potential grounds are improper.
- An objection is deficient when it states only the legal basis (e.g., relevance, burden, privilege) without explaining how the request is defective and how the responding party would be harmed by responding.
- Under Rule 33(b)(4), objections to interrogatories must be stated “with specificity.”
- Under Rule 34(b)(2)(B)–(C), objections to requests for production must be stated “with specificity,” and the responding party must indicate whether responsive materials are being withheld because of the objection.
- Courts may address improper discovery conduct through Rules 26(g) and 37 and inherent authority; sanction decisions are discretionary and may consider counsel’s good-faith conduct and remedial efforts.

## Conclusion

The court condemned both parties’ use of boilerplate discovery objections as inconsistent with the Federal Rules’ specificity and withholding-disclosure requirements, but exercised discretion to forgo sanctions based on counsel’s cooperative conduct and willingness to reform, while making clear that future violations may be sanctioned.


Liguria Foods, Inc. v. Griffith Laboratories, Inc., 320 F.R.D. 168 (N.D. Iowa 2017)