According to John: The Secret to Proper Tree Staking!

When planting new trees, our goal should be to grow trees that will stand on their own, straight and tall, after only two years in the ground. Trees without stakes are the ideal but, because they won’t stand straight on their own when we get them from a nursery, we need to stake them. If they will stand straight on their own, and remain straight, then staking should be avoided. We all want our trees to have strong trunks with tensile strength that have a greater diameter at the base of the tree than a few feet up; the key to this is movement. Tensile (or flexible) strength in the trunk requires that the tree trunk moves in the wind. There it is: the most important part of proper tree staking is allowing for movement of the trunk, so the tree should not be tied to the stake. If you remember the importance of movement to staking and growing trees, you will know more than most garden hobbyists and of many gardening professionals. This is best accomplished by positioning two or three strong stakes away from the trunk and using rubber or rubber-like tree ties that allow for the tree to move when winds or breezes blow. Also, for a first class, professional look, make sure the stakes are straight and the same height. When you are able to tell the trunk is strong and wider at the base than a few feet up, you can remove the stakes. So remember: movement, movement, movement!! It is critical for us and for the strength and health of our trees!