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In this case, the roots were still intact and buried.
Occasionally newly planted trees will develop a slight lean from soft soil conditions or inclement weather. Trees developing a lean is common and can be easily corrected by the homeowner. We make our best effort to make sure your tree is planted straight and stable. Research shows that leaving trees un-staked produces a more stable tree and stimulates root growth.
If a strong storm has completely uprooted a small tree, it needs to be carefully assessed to determine if it is salvageable.
If you notice a lean, please take. The tree below-center snapped off at the point where the two main stems joined because it began to lean dramatically. Treatment: Small trees (less than about 4 inches trunk diameter) that are leaning can be staked in the upright position (See: details). Larger trees with bends or leans that are concerning can be reduced on the side of the lean or the tree can be removed from the site.
Use slow, steady pressure so you don't damage the trunk.
This is usually not a cause for concern. However, strong winds seen in heavy storms can cause a tree to become unstable and start to lean. In some cases, the tree will begin to uproot as it leans.

This type of leaning is dangerous. Soil: When soil erodes from winds or water the roots of the tree become stumpcut.barted Reading Time: 3 mins. Dec 07, In a planting site with sandy soil that experiences frequent strong winds from one direction, many trees will start leaning away from the direction of the wind. Wet soil: Soil that is too wet- either because the planting site is in a boggy area or because of recent heavy rains- can cause a tree to be unstable. Correcting drainage patterns around the planting site might keep a tree from leaning.
Sep 12, Besides wind and lousy soil, a main reason that new trees lean is that the rootball isn't big enough to secure the canopy. Jul 03, Remove as much soil as possible from under the exposed roots and gently straighten the tree.
The roots must be replanted below grade level. Pack the soil firmly around the roots and attach two or three guy wires to the tree, anchoring them about 12 feet ( m.) from the trunk.