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It seems to really vary by state, by county and by caseworker. Earlier this year in Iowa, there was a very sad case- the older sister had been put into foster care due to severe physical abuse, but the parents were allowed to keep the infant twins, and the older daughter was returned to them. A couple months later, the infant boy was dead, and the surviving girls both showed signs of severe ongoing abuse.
I've heard of other cases where infants were taken purely on the basis of past TPRs, or where parents were offered a deal- voluntarily TPR for older children in exchange for being allowed to keep the baby.
Personally, I think if someone has major issues that will always be a barrier to parenting, someone should explain that to them and encourage them to get sterilized.
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