In Caryl Richards, Inc. v. Superior Court (1961) 188 Cal. App. 2d 300, one of the plaintiffs suffered injury to her eyes, allegedly caused by hair spray manufactured by the defendant. The plaintiffs served an interrogatory asking for the chemical composition of the hair spray, and received a response that they considered insufficient. (Id. at p. 302.) The defendant served a supplemental answer in response to an order compelling it to do so, but its answer was again deemed insufficient by the plaintiffs. The plaintiffs then filed a motion for sanctions asking the court to strike the defendant's answer and enter its default. (Ibid.) The trial court denied the motion on condition that the defendant provide a further answer within 15 days. (Id. at pp. 302-303.) Upon receipt of a supplemental answer they deemed insufficient, the plaintiffs again requested the court to strike the defendant's answer and enter its default. This time the motion was granted. (Id. at p. 303.) The appellate court vacated the trial court's order as excessive because the default sanction relieved the plaintiffs of the burden of establishing the other elements of their case and deprived the defendant of other defenses. (Caryl Richards, Inc. v. Superior Court, supra, 188 Cal. App. 2d at p. 307.) The appellate court noted that when a court imposes an order that goes beyond what is necessary to accomplish the purpose of discovery and denies a party the right to defend the action or to present evidence upon issues of fact which are entirely unaffected by the discovery procedure before it, the court has not only abused its discretion but deprived the recalcitrant party of due process of law. (Id. at p. 305.) However, the appellate court found it to be self-evident that an issue sanction establishing that the defendant's product was harmful to the human eye would have accomplished the full purpose of discovery by giving the plaintiffs the benefit of what they might have received from discovery. (Id. at p. 305.) The Court reversed an order striking defendant's answer and ordering entry of a default, because the order denied defendant "any right to defend the action or to present evidence upon issues of fact which were entirely unaffected by the discovery procedure before it." The Caryl Richards court concluded that more limited issue sanctions were appropriate. In Caryl Richards the plaintiff suffered injury to her eyes, allegedly caused by hair spray manufactured by defendant. When the defendant refused to disclose the chemical composition of its hair spray, the trial court sanctioned the defendant by striking its answer and entering a default. The appellate court vacated that ruling as excessive because the default sanction relieved the plaintiff of the burden of establishing the other elements of plaintiff's case and deprived the defendant of other defenses. The appellate court stated, however, that the purposes of discovery and the interest of the plaintiff would have been sufficiently served by a sanction order establishing that the defendant's product was harmful to the human eye. In sum, in Caryl Richards, Inc. v. Superior Court (1961) the plaintiff sought damages for injuries allegedly caused by the defendant's hair spray. (Id. at p. 301.) Despite repeated interrogatories, the defendant refused to disclose the chemical composition of its hair spray. (Id. at p. 302.) The trial court then issued an order requiring the defendant to provide the requested information. (Id. at pp. 302-303.) After the defendant provided some information, the trial court concluded that the information was insufficient to allow the plaintiff to determine whether the hair spray would injure a person's eyes and entered an order striking defendant's answer and ordering that its default be entered. (Id. at p. 303.) Caryl Richards reasoned: "While under the statute the court undoubtedly has the power to impose a sanction which will accomplish the purpose of discovery, when its order goes beyond that and denies a party any right to defend the action or to present evidence upon issues of fact which are entirely unaffected by the discovery procedure before it, it not only abuses its discretion but deprives the recalcitrant party of due process of law." (Id. at p. 305.)