Background
Plaintiff Luis Adrián Cortés-Ramos entered a music contest co-sponsored by defendant Enrique Martin-Morales and Sony Corporation. After the contest, Cortés alleged copyright infringement regarding a song released by Martin. This is the fifth appeal in twelve years for Cortés regarding these facts. The district court previously dismissed claims without prejudice to allow for copyright registration, which Cortés later obtained. Martin moved for summary judgment, arguing Cortés had assigned his rights via contest rules. The district court adopted a magistrate judge’s recommendation granting summary judgment to Martin and invalidating Cortés’s registration, but denied Cortés’s motions for discovery.
The court’s reasoning
The Court of Appeals agreed with the plaintiff that the district court erred by granting summary judgment and invalidating the copyright registration without providing the plaintiff an opportunity to conduct discovery. The court noted that the plaintiff had repeatedly pleaded for discovery to develop his case, particularly regarding the contest rules and the assignment of rights.
We agree with him on the discovery issue, so we vacate and remand for more litigation, yet again.
Cortés-Ramos v. Martin-Morales, 24-1805 (1st Cir. 2026)
What it means going forward
The case returns to the district court for further proceedings, allowing the plaintiff to conduct discovery before a final ruling on the summary judgment motion.