The doctrine of "in loco parentis" had developed both as a legal concept and as a custom in the United States. The Latin phrase meaning "in place of a parent" held schools to a high standard of care for the welfare of students. However, this legal concept was eroded by the Bradshaw v Rawling and by subsequent court rulings. The pendulum would swing back toward the medieval model, where students could enjoy significant autonomy in their choice of residence and habits.