Cortes-Ramos v. Martin-Morales, No. 19-1358 (1st Cir. 2020)Annotate this Case
The First Circuit affirmed in part and vacated in part the decision of the district court dismissing Plaintiff's claims alleging violations of federal copyright law and various Puerto Rico laws, holding that the district court correctly held that the complaint failed to state a copyright claim because it did not allege registration but that the district court erred in holding that the complaint otherwise failed to state a copyright claim and dismissing the complaint with prejudice.
Plaintiff sued Enrique Martin-Morales (aka Ricky Martin) and other unknown defendants regarding Plaintiff's music video for a music contest. Plaintiff alleged that Martin's music video for his song Vida was almost identical to the one that Plaintiff composed and created. The district court dismissed Plaintiff's claims pursuant to Fed. R. Civ. P. 12(b)(6). The First Circuit held (1) aside from registration, Plaintiff sufficiently alleged a copyright violation, and remand was required to allow the district court to consider whether the to dismiss the copyright claim without prejudice or to allow Plaintiff to supplement his complaint to allege registration; and (2) the district court correctly dismissed the state law claims.