Whether right to parent of biological parents' can be terminated by a single judge and statutorily transferred to foster parents when a parent raises their right to a jury trial?

QUESTION PRESENTED I. Whether right to parent of biological parents’ can be terminated by a single judge and statutorily transferred to foster parents when a parent raises their right to a jury trial? PROBLEM: Statutory care and protection proceedings are quasi-criminal because they bear many of the indicia of a criminal trial, and because numerous factors combine to magnify the risk of erroneous factfinding, the defendant’s interest in personal freedom, and not simply the special Sixth & Fourteenth Amendments right to a jury trial in criminal cases, trigger the right to a jury trial. II. Should parents subject to permanent termination of parental rights have federal Due Process protection to states’ right to a jury trial? PROBLEM: All states have constitutional jury right protections for civil cases, but parents are unable to raise this right in care and protection proceedings because petitioning for a jury trial right within their respective state will subject parents to permanent and irreversible injury to the familial unit due to appellate oversight or delay.