Pfeffer v. Unknown Potential

Pfeffer v. Unknown Potential · United States District Court, Middle District of Florida, Tampa Division · September 24, 2025 · No. 8:25-cv-02155

Summary

This federal district court order addresses a petition filed under the Limitation of Liability Act by a vessel owner seeking to limit liability for damages caused by his boat drifting onto a neighbor's property during Hurricane Helene. The court approves a Letter of Undertaking posted as security, issues a monition directing potential claimants to file claims by December 1, 2025, and stays all related proceedings pending resolution of the limitation action.

Court
United States District Court, Middle District of Florida, Tampa Division
Writing for the Court
Christopher P. Tuite
Jurisdiction
United States District Court for the Middle District of Florida
Decision date
September 24, 2025
Docket number
8:25-cv-02155
Procedural posture
Petitioner filed a motion to approve security, issue a monition, and stay further prosecution of claims under Supplemental Rule F.
Precedential value
nonprecedential
Parties
Philip Pfeffer
Disposition
approved

Topics

limitation of liabilityadmiraltyinjunctionscivil procedure

Practice areas

admiraltycivil procedure

Questions Presented

  1. Whether the court should approve the Letter of Undertaking as adequate security and issue a monition and stay under Supplemental Rule F.

Holdings

  1. The court approved the LOU as adequate security, ordered publication of a monition, and stayed any further prosecution of claims against the plaintiff pending appraisal or contest.

Key quotations

The LOU for the value of the Vessel in the amount of $2,000 filed by Pfeffer and Progressive is accepted as adequate security and is approved as to form and quantum. (order)

Factual background

Philip Pfeffer owned a 2019 Bayliner 210 named "Ella" that was dislodged by Hurricane Helene in September 2024, striking a neighbor's residence and causing damage to the vessel, the neighbor's property, and nearby boats. Pfeffer later sold the vessel for $2,000 and alleged total damages could exceed $700,000. He filed a complaint seeking exoneration under the Limitation of Liability Act and simultaneously moved for security in the form of an LOU signed by Progressive Express Insurance.

Procedural history

The case was filed in the United States District Court for the Middle District of Florida. The plaintiff sought limitation of liability under 46 U.S.C. §§ 30501‑30512 and filed a motion for security and stay, which is the subject of this order.

Court Document

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