Which of the following best summarizes Monahan, Shaw and Ryan's analysis of the "residual branch" of POGG? O a. The courts have rarely used the residual branch of POGG to uphold federal legislation, but they have used it in a few specific cases. O b. The courts prefer to use the residual branch in tandem with the emergency branch of POGG. c. The courts have used the residual branch more than any other branch of POGG to uphold federal legislation. O d. The courts have never used the residual branch of POGG to uphold federal legislation