undertakings in such a context could embroil the court in the merits of the underlying custody issues and would tend to dilute the force of the Article 13(b) exception. Danaipour, 286 F.3d at 25 (quoting the Brown Letter). Nevertheless, even where a district court has found grave risk arising from physical or psychological abuse, several Courts of Appeals have required district courts to consider undertakings prior to denying a petition. See, e.g., Simcox, 511 F.3d at 610-11 (remanding for assessment of whether undertakings could be fashioned to allow for return); Blondin, 189 F.3d at 249-50 (after affirming finding of grave risk, remanding for consideration whether arrangements could be made with a third party custodian to allow for repatriation). But see Baran, 526 F.3d at 1351-52 (<HOLDING>). Although this case involves domestic abuse
holding that the district court did not have jurisdiction and remanding the matter to state court holding that the court did not have jurisdiction to consider an argument not presented to the board in a motion for reconsideration holding that rule 11 sanctions imposed by district court remained in effect after case was remanded to state court upon a finding that district court lacked subject matter jurisdiction over the case holding that upon a finding of grave risk the district court did not have to consider undertakings holding that although that the district court erred in finding that plaintiffs lacked standing the appellate court may nonetheless proceed to consider the district courts determination that plaintiffs failed to state a claim upon which relief may be granted