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Rh, 243 U. S. 93 (1917).

In Pennsylvania Fire, an Arizona corporation sued a Pennsylvania corporation in Missouri for a claim arising from an insurance contract issued in Colorado and protecting property in Colorado. Id., at 94. The defendant maintained that the Missouri court lacked personal jurisdiction over it because the plaintiff’s claim had no connection to the forum. Id., at 94–95. But in compliance with Missouri law, the defendant company had previously filed “a power of attorney consenting that service of process upon the superintendent [of the State’s insurance department] should be deemed personal service upon the company.” Id., at 94. The Missouri Supreme Court construed that power of attorney as express consent to personal jurisdiction in Missouri in any case whatsoever, and this Court held that “the construction did not deprive the defendant of due process of law.” Id., at 95.

The Court asserts that Pennsylvania Fire controls our decision today. I disagree. The case was “decided before this Court’s transformative decision on personal jurisdiction in International Shoe,” BNSF, 581 U. S., at 412, and we have already stated that “prior decisions [that] are inconsistent with this standard … are overruled,” Shaffer, 433 U. S., at 212, n. 39. Pennsylvania Fire fits that bill. Time and again, we have reinforced that “ ‘doing business’ tests”—like those