What factors do courts consider when restricting where a parent can live with their child?

In the Interest of S.I.S.F., a Child

COA04 — January 28, 2026

In this SAPCR case, the Mother—who was named Sole Managing Conservator—sought to relocate with the child to either the Dominican Republic or Florida. Despite the Mother's status as the primary custodial parent, the trial court imposed a geographic residency restriction limiting the child's primary residence to Bexar County and its contiguous counties. The Fourth Court of Appeals affirmed the ruling, finding that the trial court properly applied the 'Lenz factors' and prioritized the Texas public policy of ensuring frequent and continuing contact between the child and the Father, who lived in San Antonio.