in the Interest of C.L.R., R.S.R., and C.B.R., Children, 07-15-00087-CV

Parents divorced in 2010; father is biological parent of two children (R.S.R., C.B.R.) and adoptive father of older child (C.L.R.).
After a 2012 incident in which C.L.R. accidentally injured C.B.R., the father’s relationship with C.L.R. became strained and she rarely visited him thereafter.
In 2014 the mother’s husband accepted a job ~300 miles away in Sherman; mother sought to lift a Lubbock-only geographic restriction so she could relocate with the children and be allowed to designate their primary residence.
Trial court modified the possession schedule: father received Standard Possession Order time with his two biological children; access to C.L.R. was limited to visitation at mother’s home by agreement. Mother was given the right to designate the children’s primary residence without geographic restriction.
Father appealed, arguing the modification was not in the children’s best interests and lacked sufficient evidence; mother and counselor testified relocation and keeping the siblings together favored modification.

Issue	Father’s Argument	Mother’s Argument	Held
Whether trial court abused discretion in modifying possession and lifting geographic restriction	Modification not in children’s best interest; insufficient evidence; move would impair father’s relationship and family ties in Lubbock	Move and lifting restriction are in children’s best interest to keep siblings together and for family stability/financial opportunity in Sherman	Court affirmed: no abuse of discretion; record contains substantive and probative evidence supporting modification
Whether appointment of mother to designate primary residence was proper	Father asserted loss of regular parenting role and visitation impractical if children moved; counseling needs would be impaired	Mother argued job necessity, better long-term provision, children excited and would benefit; keeping siblings together is important	Court affirmed appointment to mother; best-interest evidence supported authorizing residence without geographic restriction

In re L.C.L., 396 S.W.3d 712 (discussing abuse-of-discretion review in custody modifications)
In re H.N.T., 367 S.W.3d 901 (abuse-of-discretion standard in family law)
Jacobs v. Dobrei, 991 S.W.2d 462 (custody/possession review principles)
In re W.C.B., 337 S.W.3d 510 (abuse-of-discretion and evidentiary sufficiency overlap)
In re V.L.K., 24 S.W.3d 338 (best-interest standard primary in conservatorship determinations)
Gillespie v. Gillespie, 644 S.W.2d 449 (trial court’s latitude in child custody decisions)
In re A.L.E., 279 S.W.3d 424 (deference to trial judge’s credibility assessments)
Crawford v. Hope, 898 S.W.2d 937 (standards for appellate review in family law)
In re Ferguson, 927 S.W.2d 766 (review principles in modification cases)
Zeifman v. Michels, 212 S.W.3d 582 (best-interest considerations in child custody matters)