Legal Question in Real Estate Law in California

No. Short sale or not, you cannot get a deficiency judgment on a purchase money loan secured by a deed of trust.

First of all, creditors can't just "file" judgments......they have to file lawsuits and win them first.

Next, Mr. McCormick's answer is correct in that there can be no deficiency judgment on a purchase money loan for an owner-occupied home, but maybe doesn't completely cover all the risks and possibilities. A short sale can create an entirely new set of rights and obligations between the parties, eliminating the original borrower-lender relationship and substituting a new deal that isn't a plain vanilla purchase-money obligation. This happens fairly often in loan modification deals, and I have seen new promises that create possible future liabilities creep into short sales as well.

I think one must look at each short-sale document carefully to see if the soon-to-be former lender has slipped in something obligating the soon-to-be former homeowner to some kind of future risk.