Highs are taken in the shade, not the sun. If it is 95 F in the shade, I imagine it is 105-110 in the sun. Just my guess. But its not just the heat itself, it is the intensity of the infrared rays. I occasionally have one of my cattleya alliance plants get badly sunburned, simply getting mid-day sun for brief minutes through the tree canopy. I am not brave enough to risk any of mine to direct sun from 11:00 AM till 4:00 PM. Winter sun is an entirely different story, since the sun is so low in the sky. Fall and spring kind of fall in between. I'm just a big chicken!