For plants that have no trouble with cold temperatures I like to plant in the fall. I haven't noticed any difference between dormant bare root fruit trees/bushes and actively growing container grown plants - they both have done fine. For plants that are more tender, where I am on the edge of where they should be growing, I like to buy them in the fall but pot them up in a larger pot and protect them over the winter and plant them in the Spring.

I have had many tender fruit trees do fine in the Fall, make it all the way through Winter, start to sprout in the Spring and die sometime in March. I never seem to lose them in the bad weather, only when they are just starting to look happy.

I have around 100 different fruit trees all less than about 7 years old and most planted in the fall. It's definitely better to plant in the fall than in the spring. Peaches, apples, cherries, nectarines, pears, plums. All better in the fall. I tried pomegranates and a couple service trees, but they perished within a year of planting. Not sure the pomegranates were ready for the ground, but that's how they were advertised and I treated them the same as the others. Tried figs both mail order and from Lowe's and none of them worked out in the open. I'll keep trying them with cuttings I'm taking myself from neighbors.

Benefit to planting in the fall is that the roots are growing even if the tops aren't doing anything. The tops will start putting out red/dark brown growth in late January into February and leaves later on when they're supposed to. I've only lost a few other trees, two cherries last summer because they flooded the weekend we had 10 inches of rain here. But that's rare and the rest of the trees in the immediate area were fine. One apple elsewhere because of all the rain and probably weak root system. But all else look good. I even had a couple crabapples and pears this summer that the deer got before I could. One of these days I'll be busy... :-)

Stark Bros, One Green World (Pacific NW nursery), and Willis Orchard Co. (southern GA) are my favorites to mail order fruit trees from. All quality products for the most part, all packaged well. I like Miller nursery as well for their berry plants. And I just tried to go to their website and it says they're merging with Stark Bros, so that tells me they really did have a quality product. I hope that's what that means. :-)