I just had this happen to me the other night, but was only about 50F (it's been relatively cold here in norcal). The rest of the doors unlock, but the button on the tailgate was not responding. Only after a few cycles of locking and unlocking via remote and the interior lock button, the tailgate finally unlocked and opened.
Have you also been having issues with the car not unlocking via remote? I've also been having issues with the car unlocking via remote in the mornings. I thought my key fob batt was low, but I tried with my second key fob that barely gets used, and it didn't respond to that either until a minute or two of continuously pressing the buttons on the remotes. However when it's warmer during lunch time or in the afternoon, the car responds just fine to the keyfobs.