We always used to cross-tie them between 2 posts or trees. Answer: This depends on how much your horse likes to be bathed. If the horse stands well for being groomed and doesn't mind water, soap, etc. leave the halter on and use a lead rope to tie the horse off to a solid object ( sturdy fencing, tree etc.)or have someone else hold the lead rope while you bathe, this also gives you the ability to move the horse if the ground gets too wet or muddy ( hint: if you wash on the grass you probably won't need to move that much or if grass isn't available put down some hay.) If the horse does NOT like water or a bath use the same method but cross tie ( one lead rope from each of the cheek rings at a 90 degree angle to the horse and keep very little slack in the lead ropes)it will also help to have another person with you to work with the horse, distraction, treats and reassurance all can help to make this a more pleasant experience for the horse and you both. Also, if the horse does not like the hose, try keeping the stream of water right up against the skin, use warm water if possible and wash the head with a small towel, if that still isn't enough try blinders. Keeping the session short and starting from the rear of the horse may also give you better results...it may take a week top give the horse a bath but it will pay off in the long run.