Federal Court Limits Access to Target Training Materials and Surveillance Footage

A federal court on December 9, 2025 entered a stipulated protective order in Dixson v. Target that governs how discovery materials may be handled and disclosed. The order, signed by Judge Robert J. White, specifies categories of materials that plaintiff may obtain from Target and permits the company to designate those materials as confidential, creating significant limits on who may view them and how they are used in the case.

Key categories identified include surveillance video footage and still shots tied to the incident in the complaint, together with related metadata and information such as camera angles, the number and location of cameras, and Target video policy. Employee training manuals were explicitly listed and identified as proprietary materials containing trade secret information. The order also covers policy and procedural manuals that relate to store or corporate operations when they are designated as proprietary trade secret information.

The protective order establishes procedures for marking documents as confidential, creates two tiers of restriction including Confidential and Confidential, Attorneys Only, and requires parties to obtain confidentiality agreements before disclosing protected materials to outside individuals. It addresses the treatment of depositions and provides for sealing where appropriate. At case termination, the order requires the return of designated materials to Target.

For workers and those who represent them, the order has practical consequences. Limiting access to surveillance footage can constrain an employee or plaintiff from independently reviewing evidence of workplace incidents, and sealing training and operational manuals may make it harder to challenge company practices in public court filings. At the same time, the order is designed to protect what Target and the court deem to be proprietary information, a concern employers often raise when internal safety protocols or security systems are involved.

The stipulated nature of the order indicates agreement between the parties on confidentiality procedures, but it also illustrates a broader tension in employee related litigation between transparency and protection of corporate intellectual property and security. The order will govern disclosure throughout the litigation and shape how evidence about Target store operations and employee training is used and accessed in the case.