Idk if it's the wind that caused it or what but when I transfered my 3 week old plants to outside a few actually fell over the next day! the leaves are still pointed toward sun though and they seem to be fine... If you look close u can see the ones I'm talking about
If you dont feel like stake'n em, top off with more soil and rotate the pot clockwise/counter clockwise during the day
your better just staking them I feel if there going in the ground there to protect them from the wind, wind sucks!