The reason that justifies statement 14 (m∠C = 90°) is:
Transitive Property
This is because statement 13 states that m∠D = 90°, and statement 12 states that m∠C = m∠D (due to congruence of angles from the previous parts of the proof). By the transitive property, if m∠D = 90° and m∠C = m∠D, it follows that m∠C = 90°.