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As with other types of plants (shrubs, perennials, etc.) used in Bambi-busting, deer-resistant trees is something of a misnomer. Few trees (especially young ones) will keep a desperate Bambi at arm's length (or should I say, at branch's length?).
So if you are a stickler for linguistic detail, feel free to re-title this article (in your mind) as Trees That Are Not Deer's First Picks to Eat, When Given a Choice. Although accurate, that sounds awkward, which is why deer-resistant trees works just fine, as long as we have an understanding of its limitations.