When dismissing on forum non conveniens . . .

To the right, Elvis sings “Return to Sender.” Similarly, in Rajet Aeroservicios v. Cervantes, the Fifth Circuit reminded: “‘The failure to include a return[-]jurisdiction
clause in an [FNC] dismissal constitutes a per se abuse of discretion.” . . . This is because, as our court has repeatedly made clear, ‘courts must take measures, as part of their dismissals in  [FNC] cases, to ensure that defendants will not attempt to evade the jurisdiction of the foreign courts.’ Notably, ‘[s]uch measures often include agreements
between the parties to litigate in another forum, to submit to service of process
in that jurisdiction, to waive the assertion of any limitations defenses, to agree
to discovery, and to agree to the enforceability of the foreign judgment.’ A return-jurisdiction clause assists in preventing defendants from circumventing these measures and ensures plaintiffs have the opportunity to proceed with the action in one of the forums.” No. 19-20354 (Feb. 3, 2020) (unpublished) (citations omitted, emphasis added).