I won't plant past March where I am if I'm paying good money for a tree or shrub. If it's free it can go in anytime, anywhere. Either way, I have little to no
water to give it, so it has to fend for itself. Hardy plants sometimes come through, even in difficult situations. I just won't spend money for what could be a catastrophe.
I tend to believe that the "second spring" that starts at the end of August where I live is good for plants. It gives them a gentle immersion in the site they will be permanently and it does so at a time when they are less active. If you plant in spring the plant is putting
energy into the leaves, not the roots. If you plant in summer, in many temperate climates the situation is far to hot for a plant to begin life successfully.
Now,
If you have cool summers, the plant is slightly shaded, you have ample access to mulch material, and can water every day about 200 liters or more per plant in a drought situation, then go for it. I don't have that situation, so I have to let nature do all that for me, which means waiting for fall. I find that the prices for plants are high in the spring where I am. People get their green thumb ideas around the start of May, and the nurseries try to capitalize on that.
William