This paper derives the Ziv-Zakai lower bound (ZZLB) for the time of arrival (TOA) estimation in the presence of one interfering pulse from which no a priori knowledge is available. The bound is obtained by including the interference in the system model but only the transmitted pulse as a candidate for the likelihood ratio (LR) test. A compact ZZLB expression that depends on the time delay and amplitude of the interference is obtained. We compare the performance of the first path maximum likelihood estimation (MLE) with the bound as a function of the relative distance between the first path and the interfering path.