A recent Florida appellate case shows how even the largest storage companies can lose a lawsuit by missing one simple detail: updating a tenant’s address.

In Krocka v. Public Storage, Inc., a long-term storage tenant mailed the company a certified letter giving his new address and his agent’s updated contact information. The company acknowledged receiving it; but a year later, when rent went unpaid, it sent the auction notice to the old address and sold the unit’s contents.

The tenant sued, and the court ruled the sale was invalid because Florida’s self-storage lien law requires notice to be sent to the tenant’s last written address. The court emphasized that even a simple letter qualifies as a valid change-of-address notice, and that phone calls or voicemails don’t count as legal notice.

The Result

Public Storage lost on appeal. Now the case stands as a warning to all Florida storage operators:

• Follow the self-storage lien statute to the letter.
• Treat every written address update as binding.
• Keep organized, name-based records — not just by unit number.

A small paperwork error can turn a lawful lien sale into a major legal problem.

Want the Full Analysis?

Our members-only article breaks down this case step-by-step, explains how to structure your notices, and includes sample compliance procedures for Florida storage facilities.

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