The different magnetic behaviors of LaCoO$_3$ films grown on LaAlO$_3$ and SrTiO$_3$ are related to the Co-O-Co bond angles and the constraints imposed on the Co-O bond lengths by the substrate geometries. Long-range magnetic order occurs below T ~ 90 K when the Co-O-Co bond angle is greater than 163 degrees, consistent with the behavior of bulk and nanoparticles forms of LaCoO$_3$. A LaAlO$_3$ substrate prevents magnetic long-range order at low temperatures near the film-substrate interface and collinear antiferromagnetic sublattices away from the interface. At low temperatures, the antiferromagnetically ordered sublattices are non-collinear in films grown on SrTiO$_3$ substrates, leading to a significant net moment.
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