February 6, 2026
Court of Appeal of the State of California, Second Appellate District, Division Six
The Rule of In re Marriage of Danielle and Lewis Allen is that parents are precluded from contractually waiving or forgiving past due child support arrearages even after the child has reached the age of majority and there is no longer a current support order in place, under circumstances where the obligor seeks to enforce an accord and satisfaction agreement for less than the full arrearage amount.