I think it is D.) establishment of the supreme court
Explanation:
because the stuff that the paragraph said was relating to how the king could make his own laws to stay in power, so they needed a thing to prevent that in America.
I think it is the last one (establishment of the supreme court) because the stuff that the paragraph said was relating to how the king could make his own laws to stay in power, so they needed a thing to prevent that in America.