Paul and Dan are involved in a traffic accident at an intersection where there is a traffic circle but no posted signs or traffic lights. They are in agreement as to everything that happened in the accident, including the locations of the two cars and the timing of events leading to the accident. Based on their pleadings and on information obtained during discovery, the only dispute they have is the interpretation of the state law affecting who had the right of way when they collided. The appropriate motion for one of the parties to file is:

a. Motion for judgment on the pleadings.
b. Motion for judgment n.o.v.
c. Motion for dismissal.
d. Motion for summary judgment.