The US Court of Appeals for the First Circuit has vacated a summary judgment ruling in favour of singer Ricky Martin in a copyright infringement case.
The court found that the district court had improperly resolved key factual issues without first allowing the plaintiff to obtain discovery.
The case, Luis Adrián Cortés-Ramos v. Enrique Martin-Morales, a/k/a Ricky Martin, was decided on 12 June 2026 by Judges Thompson and Aframe, with Judge Barron dissenting in part.
The dispute originated when Cortés-Ramos submitted a song and music video to a contest sponsored by a recording studio and Ricky Martin for inclusion on the 2014 FIFA World Cup official album.
After Martin released the song “Vida,” Cortés-Ramos alleged that the track infringed his copyrighted work and initiated legal proceedings.
Martin defended himself on the ground that Cortés-Ramos had assigned his copyright to the recording studio by agreeing to the contest rules at the time of submission.
Cortés-Ramos disputed this, contending that he never received those rules despite signing documents that acknowledged compliance with them.
The district court had adopted an expedited summary judgment schedule that effectively foreclosed any discovery, concluding that Cortés-Ramos had assigned his rights to the recording studio.
Based on that conclusion, the district court also ruled that Cortés-Ramos’s copyright registration was invalid, a decision the First Circuit likewise vacated on appeal.
The First Circuit agreed that the district court properly exercised jurisdiction, noting that Martin could not be compelled to arbitrate under an agreement to which he was not a party.
The court cautioned, however, that factual findings made in the litigation could carry preclusive effect in a parallel arbitration between Cortés-Ramos and the recording studio.
On the core discovery issue, the First Circuit found it fundamentally unfair to resolve dispositive matters while denying Cortés-Ramos access to evidence held by the recording studio and Martin.
Although Cortés-Ramos had not formally moved under Federal Rule of Civil Procedure 56(d), the court treated his repeated discovery requests as functionally seeking relief under that rule.
The First Circuit vacated both the summary judgment order and the copyright registration invalidity ruling, remanding the matter to the district court for further proceedings.
The ruling serves as a significant reminder that courts must allow meaningful discovery before resolving ownership disputes that hinge on evidence outside a plaintiff’s possession.