Shakeel Uddin v. Jacqueline K. Cunningham Deputy Receiver of Southern Title Insurance Corporation and Southern Title Insurance Corporation
Appellant Shakeel Uddin appealed a summary judgment granted to Southern Title Insurance Corporation (STIC). Uddin had guaranteed a loan to Nabeel & Amaan Investments, Inc. (NAI), which defaulted, leading to a claim by the lender, Sterling Bank, under a title insurance policy issued by STIC. After paying Sterling and being assigned the loan rights, STIC sued Uddin directly on the guaranty. Uddin argued that the claim was barred by the statute of limitations and that he had raised material issues of fact on his affirmative defenses. The First District Court of Texas affirmed the trial court's judgment, concluding that the statute of limitations was not jurisdictional, STIC's capacity issue was cured by the relation-back doctrine, STIC established its claim, and Uddin had contractually waived his other affirmative defenses.