This article discusses a California case which held that junior lienors may reach the surplus following a trustee sale without regard to any automatic homestead exemption, although only after the exempt amount has been first set aside for the debtor when there is a declared homestead exemption.
Bernhardt, Roger, "The declared homestead exemption: Title Trust Deed Serv. Co. v Pearson, 2005" (2005). Publications. 391.