If the tree grew in a sheltered spot and was transplanted to a more open environment its trunk will not have developed the necessary fibers to withstand winds well especially if you consider most transplanted deciduous trees are leggy– that is they are mostly trunk and all their leaves are at the top and act as windcatchers to tip the little guy. If you stake the tree (tied with rope), there will be more stability against wind. Once a better root system develops and the trunk a climates to the wind you can remove the stakes.
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