"Yes, judges are independent, and the Founders thought that this independence would protect their ability to uphold the law, even when doing so is unpopular. On the other hand, this independence can look like unaccountability and it can create what the great legal scholar Alexander Bickel called the 'countermajoritarian difficulty.' Throughout our history, many of the Supreme Court's most contested decisions have been in cases—think of cases involving, for example, gun regulations or abortion restrictions—where the Justices struck down duly enacted laws and, critics contend, acted against the will and legitimate choice of the majority."—Richard W. Garnett
Which statement is a counterpoint to the idea of "countermajoritarian difficulty" described in the excerpt?

a) As noted in Federalist No. 78, the judicial branch is weaker than the other branches.

b) As noted in Federalist No. 78, judicial freedom is an essential constitutional safeguard.

c) In Marbury v. Madison (1803), the Court ruled that the Constitution must be interpreted literally.

d) In Marbury v. Madison (1803), the Court ruled that the judicial branch gains power through review.

*** The answer is NOT "d) In Marbury v. Madison (1803), the Court ruled that the judicial branch gains power through review."