I'm embarrassed to admit this but I screwed up and tied my trees tight to the stake. After a couple of years when the garden tape I used started to break my trees were like noodles, falling over against the cages. I went with a heavy string like Jack did to give them some sway, but still have several that have not "stiffen up" yet. So as it's been said above if you go with a stake leave the tree some room to sway in the wind.