I believe this is a restriction of $or and geo queries in version 2.6:
$or and GeoSpatial Queries
Changed in version 2.6.
$or supports geospatial clauses with the following exception for the near clause (near clause includes $nearSphere and $near). $or cannot contain a near clause with any other clause.
http://docs.mongodb.org/manual/reference/operator/query/or/
In other words, not a bug but a feature