In California, can definitions be used in preparing special interrogatories?
Yes. In California, you may use defined terms in specially prepared interrogatories, but the definitions must comply with the statutory formatting rules. Specifically, any term specially defined in a set of interrogatories must be typed in all capital letters wherever it appears, and the interrogatories must still be separately numbered, full and complete in themselves, and may not include subparts or compound questions.[1][4]
Governing California Rules
The key statute is Cal. Civ. Proc. Code § 2030.060:
“Any term specially defined in a set of interrogatories shall be typed with all letters capitalized wherever that term appears.” Cal. Civ. Proc. Code § 2030.060(e)[1][4]
That means definitions are allowed, but the drafting must be careful:
| Rule | Practical effect |
|---|---|
| Each interrogatory must be “full and complete in and of itself” | Avoid cross-references that make the question incomplete without the definitions section |
| No preface or instructions unless approved | Keep any instructions limited to approved language |
| Defined terms must be capitalized everywhere they appear | Example: define “INCIDENT,” then use “INCIDENT” consistently |
| No subparts, compound, conjunctive, or disjunctive questions | Definitions do not permit combining multiple questions into one interrogatory |
Practical drafting point
You can include a definitions section at the beginning of a set of special interrogatories, but each interrogatory still has to stand on its own and comply with the no-subparts rule.[1][4] So, for example, this is generally acceptable:
“For purposes of these interrogatories, ‘INCIDENT’ means the automobile collision that occurred on March 1, 2025.”
Then use:
“State all facts supporting your contention that INCIDENT was caused by YOUR CLIENT.”
That said, you should be cautious not to overdefine ordinary terms in a way that makes the interrogatory ambiguous or overly burdensome.
Related limit on number of interrogatories
California generally allows 35 specially prepared interrogatories as a matter of right, unless a declaration supports additional interrogatories under Cal. Civ. Proc. Code § 2030.040 and related provisions.[2][3] Definitions are often used to make those interrogatories more efficient, but they do not change the numerical limit.[2][3]
Bottom line
Definitions may be used in California special interrogatories, and the Civil Discovery Act expressly contemplates specially defined terms.[1][4] The main drafting requirement is that the defined term must be capitalized wherever used, and each interrogatory must remain complete and single in form.[1][4]