All payments court ordered can not be discharged in Bankruptcy.
Many times the court orders payments that are to make of for past bad deads such as taking or destroying someone else's property without permision. This is not a credit situation. They didn't borrow anything and the person receiving the payments didn't willingly extend any credit.
Yet the payments can be ended through a bankruptcy claim.
http://www.notesfromthefarm.com/article.php/20060512202444798