As this decision explains, Civil Code 2911 provides that a lien is extinguished when the statute of limitations has run on the principal obligation that the lien secures. This statute has limited application to deeds of trust. While the lien of a deed of trust that is enforceable by judicial action (i.e., a judicial foreclosure action under CCP 725a) expires when the 10-year statute of limitations runs on the note the deed of trust secures, the beneficiary can still non-judicially foreclose on the deed of trust until the time limit set by the Marketable Record Title Act (Civ. Code 880.020 et seq.) expires. That time limit is 60 years from the date the deed of trust is recorded unless the final maturity date of the note can be determined from the face of the recorded deed of trust, in which case, the limit is 10 years after that date.