Rivera v. Orange County Probation Department (In Re Rivera)

OPINION

REINHARDT, Circuit Judge:

Introduction

We must decide whether a mother’s debt to Orange County arising from her son’s involuntary juvenile detention is a “domestic support obligation” and thus excepted from discharge in bankruptcy. We conclude that it is not.

Factual Background

Appellant Maria Rivera is the mother of a minor who was held in juvenile detention in Orange County for more than a year, from 2008-2010. Upon her son’s release, the County Probation Department sent Rivera a bill.

California law makes the parents of juvenile detainees “liable for, the reasonable costs of support of…