Garden Cress (cool-season leafy green) is classed tender in the cited extension guidance. The timing rules below are relative to your local freeze dates — enter a location to turn them into calendar dates.
The rules this site applies
Method
Frost-relative window
Rule & reconciliation
Direct-sow outdoors
from the median last spring freeze to 2 weeks after
Utah State University Extension says garden cress "does not tolerate frost so plant near the frost free date", and Arkansas Extension's culture line reads "seed shallow depth after danger of frost"; both open at the last spring frost, and this later interval supersedes Arkansas' looser "as soon as the ground can be worked" sentence, giving last spring frost to plus 14 days.
Variety assumption: Offsets are for garden cress (Lepidium sativum), a 10–40 day cutting green; watercress and upland cress are different species with different requirements and are not covered by this entry.