State v. Luis G., 2009AP1313-CR, District I, 2/17/2010

court of appeals decision

TPR – Forfeiture of Jury Trial

Failure to appear at initial hearing and make timely request forfeited right to jury trial; trial court’s ultimate refusal to enter default judgment “did not return the case to the initial hearing stage or reinstate Luis’s right to a jury trial”; nor did filing of amended petition reset this clock; finally, the court suggests that denial of right to jury trial was, even if erroneous, harmless, because “(a) jury trial would not have led to a different outcome,” ¶35, given the strength of evidence on grounds—an odd aside, given that denial of right to jury is generally thought not subject to harmless error analysis.