Floribundas and polyanthas usually are well behaved and easy to keep in line, but you never know what's going to happen with other classes of roses. I've moved minis out of containers into rose beds, carefully planting them in front, but they invariably put on a growth spurt when they get out of the containers and start dwarfing all of the floribundas behind them. It doesn't help that I have a preference for mini-flora roses -- the minis that already grow up to 3 feet in most gardens and run wild when they get into mine.