When you’re toenailing a piece, it’s pretty tough to keep it in place as you hammer. Here are some ideas to do it right.
If you’re doing a bunch of regularly-spaced items, such as studs nailed in place after the wall is up, simply cut a piece of 2x the length of the gap (14.5″ in the case of 16″ centers). Place it on the plate piece against the previous stud, and position the next stud in place at the other end. Hammer away.
You can do something similar using a prybar. Put the piece you’re toenailing in position, and place a prybar on one side, on top of the piece you’re nailing into. Hammer the prybar so the claws bite into the wood and fix it in position. Then do your toenailing.
Using screws is often a good alternative to nails, since you’re not pounding against the piece you want to stay in position.
Pre-drilling is another way to make driving easier, whether you’re using nails or screws.