A lot of comes down to disc selection and the rotation you are putting on the disc and which side of the tree you are hitting.
If you're throwing a champ driver and it's spinning hard it's going to kick hard no matter where it goes if it's a glancing blow so chances are it's probably not going to land in the fairway. If you're throwing a pro putter it's not going to kick very far even if it goes straight towards the woods you'll probably not be in a totally bad place.
The theory also doesn't account for shots that go 6' in to the woods and then magically come barreling back out which is what I consider tree love more than anything. If you barely nick a tree right at the edge of a fairway that's not really what I could tree love.
If you're throwing a champ driver and it's spinning hard it's going to kick hard no matter where it goes if it's a glancing blow so chances are it's probably not going to land in the fairway. If you're throwing a pro putter it's not going to kick very far even if it goes straight towards the woods you'll probably not be in a totally bad place.
The theory also doesn't account for shots that go 6' in to the woods and then magically come barreling back out which is what I consider tree love more than anything. If you barely nick a tree right at the edge of a fairway that's not really what I could tree love.