It is one of those things where there is no definite answer. Hunter pressure has a lot to do with where deer bed, but I have actually watched deer bed down near me in Bow and Rifle season with no logical explanation as to why they chose that spot. If you spend a couple days out and there is snow on the ground, the beds usually seem to have no pattern at all. If you find a good food source in the woods where the deer have been scraping the snow and leaves away to feed, that area would be a more reliable place as long as the food holds out.