Case Summary:
The County initiated this adversary proceeding contending that a debt owed to it was non-dischargeable.  The debt consisted of fees incurred by a guardian ad litem and two other members of a custody assessment team in response to motions brought by the Debtor.  The Court held that the debt was a non-dischargeable domestic support obligation under 11 U.S.C. § 523(a)(5).  Because state law charged the members of the custody team with a duty to act in the best interest of the child, fees they incur would almost inevitably be domestic support obligations.  Only if the Debtor could show a total lack of nexus between the activities and the support of a child might the fees be dischargeable.  Since the Debtor failed to make that showing, the fees could not be discharged.

Statute/Rule References:
11 U.S.C. § 101(14)(a)
11 U.S.C. § 523(a)(5) -- Nondischargeability - Divorce Decrees
Wis. Stat. § 767.405(14)
Wis. Stat. § 767.406(4)

Key Terms:
Domestic Support Obligation
Guardian Ad Litem (GAL)
Non-Dischargeable Debt