I've had that happen when the hot sun hits the wet leaves, so I try to make sure the leaves don't get wet.

Also, make sure all the soil in the pot is getting wet. I lost my last Bay because the water wasn't soaking in and just running out the bottom of the pot.

Then there are the ant nests that ruin the roots.... but perhaps that is a California problem.

Thank you westelle. I thought that may be the problem ... often it's the simplest of things that are our garden problems.

I had giant ants in my strawberry pot in which I grow cherry tomatoes but I got rid of them with soapy water and vinegar water (eliminates them and their trails) but I haven't seen evidence in the Bay Tree pot. I did then discover a small spider's web which I sprayed with soapy water but I wouldn't have thought that would cause the brown leaf problem.

Again, thank you for answering.

Could it be rootbound? Bay trees develop matted root systems if not potted on regularly, which can then rot or dry out easily.