In re Foster, 319 F.3d 495 (9th Cir. 2003)
    Interest on nondischargeable child support continues to accrue after a chapter 13 petition is filed and survives a chapter 13 discharge.

In re Leibowitz, 217 F.3d 799 (9th Cir. 2000)
    Debtor could not discharge unaccrued child support obligation assigned to county where bankruptcy petition came after changes in welfare law designed to make such debts nondischargeable.

In re Cervantes, 219 F.3d 955 (9th Cir. 2000)
    An absent parent who owes money to a county for child support payments, but as to which no child support order has yet entered, may not discharge the debt in either a chapter 7 or chapter 13 case.