Bay leaf tree & deer
Do deer eat the leaves of a bay leaf tree?
Certified GKH Gardening Expert
Even if the tree states deer resistant, the rule of thumb is that a deer will probably eat it. The only good way to keep deer out is to put fencing around the shrubs. You can also try boiling sliced hot peppers in water, and spraying the plants when it cools. This is only a temporary fix, though.