I get about 5 psi difference when doing the Pathfinder tires, sunny vs shady side. So I just make sure that I do it early enough in the day, or on cloudy days.
Of course the Pathy tires have much more sidewall surface area than those on a typical car, so more heating seems to happen.
Also, air pressure can impact psi. Maybe you checked them when you had a low pressure system sitting over you

And was there a significant change in temperature between checkings? That also impacts psi.