An unsecured creditor (i.e. a creditor without collateral) that obtains a judgment may enforce the judgment by forcing the sale of assets of the judgment debtor.  However, the state law of each state exempts certain kinds and amounts of assets of individuals (e.g. household goods, wearing apparel, health aids, retirement benefits) from forced sale.  Most states exempt some equity in a home.  California exempts up to $125,000 in equity, the amount depending upon the debtor's marital status, age, health, or income.  In California, the filing of a Declaration of Homestead is one of two methods for invoking this exemption.   Exemptions only protect an asset against forced sale by an unsecured creditor; they do not protect a home, or equity in a home, from foreclosure by one to whom the debtor has granted or mortgage (or its functional equivalent a deed of trust).  That is why Bank of Tahoe argues that Beulah's promissory note was secured by an equitable mortgage and why Buelah argues that the bank was simply an unsecured creditor.