On June 12, 2026, the U.S. Court of Appeals for the First Circuit vacated a summary judgment entered for Enrique Martin-Morales, known professionally as Ricky Martin, in the long-running copyright dispute arising from the 2014 SuperSong contest. The panel held that the district court abused its discretion by granting summary judgment, and by invalidating the plaintiff's copyright registration, without affording him any meaningful opportunity to conduct discovery. Cortés-Ramos v. Martin-Morales, No. 24-1805 (1st Cir. June 12, 2026).
Judge Thompson wrote for the panel. Chief Judge Barron dissented in part. The court noted the appeal was the fifth in twelve years arising from the same core facts, across three separate cases. For entertainment companies, contest sponsors, and litigators in this circuit, the decision carries consequences well beyond the parties.
In 2013, Sony and Martin co-sponsored the SuperSong contest, inviting entrants to submit an original composition and music video for potential inclusion on the 2014 FIFA World Cup official album. Luis Adrián Cortés-Ramos entered, advanced as one of twenty finalists, and signed notarized documents at the sponsors' request. Another entrant won. Martin later released the song and video "Vida," which Cortés-Ramos alleged copied his submission. Litigation followed against Sony and Martin in various configurations, producing four prior First Circuit appeals and an intervening dismissal tied to the Supreme Court's registration ruling in Fourth Estate. Fourth Est. Pub. Benefit Corp. v. Wall-Street.com, LLC, 586 U.S. 296 (2019).
In the current case, the district court denied the plaintiff's requests for a scheduling conference, stated it would resolve the dispositive questions at summary judgment specifically to avoid discovery, and set a one-month deadline for the motions. A magistrate judge recommended judgment for Martin on the ground that the contest rules assigned the plaintiff's copyrights to Sony and that the plaintiff had assented to those rules. The district court adopted the recommendation in full and went further, declaring the plaintiff's copyright registration invalid. No discovery ever occurred.
The panel first disposed of the plaintiff's arbitration argument. The contest documents contained an arbitration clause between the plaintiff and Sony, and the plaintiff contended the clause deprived the federal court of jurisdiction. Circuit precedent forecloses that position. An agreement to arbitrate does not divest a court of jurisdiction, and Martin, a non-signatory the court had already held was no intended third-party beneficiary, could not be compelled into the Sony clause. The panel did note that rulings in the federal case may carry issue-preclusive effect in any future arbitration against Sony, a point that shaped its discovery analysis.
The discovery holding is the decision's core. Rule 56(d) permits a nonmovant to show it cannot present facts essential to its opposition and to obtain deferral, denial, or time for discovery. The plaintiff never filed a formal Rule 56(d) motion or affidavit. The panel held that omission non-fatal. It treated his same-day motion for reconsideration of the scheduling-conference denial, and his repeated protests thereafter, as the functional equivalent, invoking the First Circuit's instruction that courts construe such requests generously and hold parties to the rule's spirit rather than its letter. In re PHC, Inc. S'holder Litig., 762 F.3d 138, 143 (1st Cir. 2014).
Applying the five-factor framework from Emigrant Residential LLC v. Pinti, covering authoritativeness, timeliness, good cause, utility, and materiality, the panel relaxed the formal requirements in light of two circumstances. The evidence sat in the hands of Martin and third-party Sony, a factor the caselaw weighs heavily in favor of relief. Because the plaintiff and the court saw only the documents the movant chose to produce, the panel observed that Martin might as well have said, "Trust me, there's nothing else to see." And the case involved no discovery at all, a posture in which denying Rule 56(d) relief and proceeding to summary judgment is typically an abuse of discretion. The panel gathered agreeing authority from the Third, Fifth, Sixth, and Ninth Circuits. It also rejected the district court's reliance on the plaintiff's failure to make initial disclosures, reasoning that a court that fast-tracks a case expressly to avoid discovery cannot then fault the nonmovant for the absence of the discovery process.
The panel vacated both the summary judgment and the order invalidating the copyright registration, directing the district court on remand to clarify the parties' discovery obligations before any renewed summary judgment practice.
Chief Judge Barron would have affirmed. In his view, the plaintiff never actually advanced the Rule 56(d) arguments the majority credited, failed on appeal to engage the district court's reasoning under Rules 26 and 45, and left unchallenged the magistrate judge's independent finding of assent through a clickwrap agreement. The dissent signals that the majority's generosity toward informal Rule 56(d) invocations has limits, and that future litigants should not read the decision as excusing undeveloped briefing.
The case returns to the District of Puerto Rico for discovery and, in all likelihood, another round of dispositive motions. Twelve years in, the SuperSong dispute is not finished.
Maceira Zayas litigates entertainment, commercial, and copyright disputes in the District of Puerto Rico and the Commonwealth courts, with an appellate practice that includes precedent-setting proceedings before the Supreme Court of Puerto Rico in the entertainment industry. The firm's litigation team is drawn from the bench and the Office of the Solicitor General. Reach us at info@mzls.com.
