The term in loco parentis, Latin for "in the place of a parent" refers to the legal responsibility of a person or organization to take on some of the functions and responsibilities of a parent. Originally derived from English common law, the doctrine is applied in two separate areas of the law. First, it grants educational institutions such as colleges and schools discretion to act in the best interests of their students, although not allowing what would be considered violations of the students' civil liberties. Second, this doctrine may allow a non-biological parent to exercise the legal rights and responsibilities of a biological parent if they have held themselves out as the parent. The in loco parentis doctrine is distinct from the doctrine of parens patriae, the psychological parent doctrine, and adoption. Situation specific Boarding schools Caretakers and management of a boarding school have the duty of care in place of the parent. Education Primary and secondary education Cheadle Hulme School, originally known as the Manchester Warehousemen and Clerks Orphans Schools, formed in 1855, adopted in loco parentis as its motto, well before the world's first public education act, the Elementary Education Act 1870. The first major limitation to this came in the U.S. Supreme Court case West Virginia State Board of Education v. Barnette (1943), in which the court ruled that students cannot be forced to salute the American flag. More prominent change came in the 1960s and 1970s in such cases as Tinker v. Des Moines Independent Community School District (1969), when the Supreme Court decided that "conduct by the student, in class or out of it, which for any reason – whether it stems from time, place, or type of behavior – materially disrupts classwork or involves substantial disorder or invasion of the rights of others is, of course, not immunized by the constitutional guarantee of freedom of speech." Adult speech is also limited by "time, place and manner" restrictions and therefore such limits do not rely on schools acting in loco parentis. In Tinker v. Des Moines Independent Community School District (1969), the Supreme Court held that for school officials to justify censoring speech, they "must be able to show that [their] action was caused by something more than a mere desire to avoid the discomfort and unpleasantness that always accompany an unpopular viewpoint," allowing schools to forbid conduct that would "materially and substantially interfere with