In CSX Transp. v. McBride, Justice Thomas joined the four justices from the liberal wing of the Court to agree to a broad plaintiff-friendly interpretation of the Federal Employers' Liability Act and whether it required a showing of proximate causation before liability would be imposed, in an opinion written by Justice Ginsburg. Chief Justice Roberts wrote a dissent, arguing that the majority opinion was confusing language abrogating contributory negligence with a diversion from the common-law principle of proximate cause. "[T]he causation test the Court embraces contains no limit on causation at all."