I dont have deer here. But bugs got a few of those.Don't plant directly under the tree.
First usually not enough light gets to the plant.
Second you don't want falling apples hitting your baby!
Last don't forget about the bugs, they'll eat the shit out of your plants.
Oh i usually wear an old sock around for a few days, let it get good and stinky, and tie strips of it near your plants........The deer will stay far away!!