In Fuentes v. Jasso, No. 08-03-00109-CV, 2004 WL 1078498 (Tex. App.--El Paso May 13, 2004, no pet.) (mem. opinion), the court considered a custody order that did contain a residency restriction.
The father had the right to designate his son's residence, but that residence was restricted to El Paso. The father moved to Tucson, Arizona.
He asked that the geographic limitation be lifted. The mother responded by asking for the right to designate her son's residence.
The trial court ruled in the mother's favor.
The El Paso Court affirmed. It found that, when the father moved, the conflict between the father's right to designate his son's residence and the residency restriction made the custody order unworkable and ripe for modification.