What is the test for terminating a natural parent's parental rights in a dependency proceeding?

Natural parents have a "fundamental liberty interest . . . in the care, custody, and management of their child . . . ." (Santosky v. Kramer (1982) 455 U.S. 745, 753.) Consequently, due process requires proof of parental unfitness by clear and convincing evidence before the state may terminate parental rights to a child. (Id. at p. 769.) However, "a finding of parental unfitness is not necessarily required at the point when parental rights are terminated. In a dependency proceeding, due process is satisfied if

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