In Lenz v. Lenz, 79 S.W.3d 10 (Tex. 2002) the supreme court addressed the application of the public policy set forth in Tex. Fam. Code Ann. 153.001(a) (West 2008) in the context of geographic restrictions. Section 153.001 provides in relevant part as follows: (a) The public policy of this state is to: (1) assure that children will have frequent and continuing contact with parents who have shown the ability to act in the best interest of the child; (2) provide a safe, stable, and nonviolent environment for the child; and (3) encourage parents to share in the rights and duties of raising their child after the parents have separated or dissolved their marriage. Lenz involved an appeal from a modification order allowing a joint managing conservator to relocate to Germany and designate Germany as the children's primary residence. The supreme court first noted that in all suits regarding conservatorship and possession of and access to children, the best interest of the children "'shall always be the primary consideration of the court . . . .'" Id. (quoting Tex. Fam. Code Ann. 153.002 (West 2008)). Observing that the family code is silent as to specific factors that the factfinder should consider in determining the best interest of the children in the context of geographic residency restrictions, the supreme court concluded that the public policy set forth in section 153.001(a) of the family code provides a framework for building guidelines for reviewing residency restrictions. Id.; see also Tex. Fam. Code Ann. 153.001(a). Because it was facing an issue of first impression in applying the state's public policy imperatives to interpret the modification standards in the relocation context, the Lenz court reviewed various factors considered by other jurisdictions, which the supreme court found to be based on a best-interest standard and thus reflective of this state's public policy. 79 S.W.3d at 14-16. The Texas Supreme Court provided a variety of factors relevant to the determination of whether a geographic restriction is in the best interest of the child, including: (1) the reasons for and against the move, including the parents' good faith motives in requesting or opposing it; (2) comparison of education, health, and leisure opportunities; (3) the degree of economic, emotional, and educational enhancement for the custodial parent and the child; (4) the effect on extended family relationships; (5) accommodation of the child's special needs or talents; (6) the effect on visitation and communication with the noncustodial parent to maintain a full and continuous relationship with the child; (7) the possibility of a visitation schedule allowing the continuation of a meaningful relationship between the noncustodial parent and the child; (8) the noncustodial parent's ability to relocate. Id. at 15-16. In doing so, the supreme court recognized that cases such as these are intensely fact-driven and therefore involve the balancing of these numerous factors, as opposed to formulaic tests. Id. Further, the supreme court noted that "no bright-line test can be formulated. Suits affecting the parent-child relationship are intensely fact driven, which is why courts have developed best-interest tests that consider and balance numerous factors." Id. at 19 .