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In our area, if we're just talking 32 degrees or a bit less for the night, it's okay, but most have them half buried in compost or chips.
There are two aspects at least:
1. Root kill temps, and 32 is not that low usually.
2. Dehydration - frozen water can't move up into the tree.
But if it's just overnight, and just hovering around "freezing" - probably no big crisis for a while.
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