Boilerplate Objections Don’t Cut It: First Baptist Church of Kenner v. Safepoint Insurance Company
First Baptist Church of Kenner v. Safepoint Insurance Company, No. 23-2858 (E.D. La. Sept. 5, 2025)
Why This Alert Is Important
This ruling reinforces a consistent message from federal courts: boilerplate discovery objections—especially generic “general objections”—risk waiver and will not preserve limits on discovery. For e-discovery practitioners, the opinion is a reminder that specificity is not optional; it is mandated by FRCP 33 and 34.
Overview
In First Baptist Church of Kenner v. Safepoint Insurance Company, No. 23-2858 (E.D. La. Sept. 5, 2025), the plaintiff sought to recover for Hurricane Ida property damage. After serving discovery on July 10, 2025, the Church received no timely responses and moved to compel. Safepoint eventually served responses—after the motion was filed—and argued the dispute was moot.
But the responses opened with 13 “General Objections,” cited en masse as “See General Objections” for nearly every answer, and offered several nonspecific objections such as “overly broad and unduly burdensome.” Defendant also failed to identify which particular request (or which part of the response to any particular request) was addressed by which of the 13 objections. The Church argued all non-privilege objections were thereby waived.
The court evaluated the adequacy of the objections under Rules 26, 33, and 34.
Ruling Summary
- Objections Must Be Stated “with Specificity”
The court grounded its decision in the black-letter requirements of Rules 33(b)(4) and 34(b)(2)(B), both of which mandate that discovery objections be stated “with specificity.” Safepoint’s 13 “General Objections”—recited wholesale and incorporated into every response via “See General Objections”—failed to identify which objection applied to which request and why. Because they did not satisfy the specificity standard, the court overruled them as improper. - Parties Must Say Whether Documents Are Being Withheld
The ruling emphasized that FRCP 34(b)(2)(C) obligates a responding party to state whether any materials are being withheld on the basis of an objection. Safepoint’s statements that documents were produced “subject to and without waiving said objection” did not disclose whether anything was withheld, violating the rule. Similarly, nonspecific assertions that requests were “overly broad and unduly burdensome” lacked the explanation necessary to show what information was implicated or what burden was at issue. These deficiencies rendered the objections inadequate. - Proportionality and Privilege Requirements Drive the Remedy
Rather than deem all non-privilege objections waived, the court applied FRCP 26(b)(1)’s proportionality framework—requiring clarity to evaluate scope and burden—and ordered Safepoint to serve revised responses that specify any withholding and articulate request-specific justifications. For any material withheld as privileged, FRCP 26(b)(5)(A) requires an express assertion of privilege and a description sufficient to allow assessment. The court required Safepoint to produce a privilege log or otherwise meet that rule’s requirements within 14 days.
Discovery disputes continue to be at the forefront of judicial proceedings despite almost two decades of rule making and jurisprudence. Organizations who choose the easy path in responding to discovery requests can expect to be challenged in court and face judicial scrutiny. Overboard objections to discovery requests are especially unfavorable. The FRCP provides clear instructions that cannot be overlooked or short-cutted. All parties are required to act in accordance with these rules.Nancy Patton, Esq., CEDS, Senior Director, Solutions Engineering, Exterro
Data Privacy Tip
This opinion reinforces a trend: courts expect granular, request-level specificity, not stock objections or blanket reservations.
