Al-Zaylaʿī likewise reproduces it in Naṣb al-Rāyah 2/142 from the Muwaṭṭaʾ, so the report once again proves to be restricted to the Ẓuhr Prayer and the time of its zenith; in fact it stands as evidence against him, not for him.
A similar, indeed even clearer, report is the authentic ḥadīth of ʿAbd Allāh b. al-Sāʾib: “The Messenger of Allah ﷺ used to pray four rakʿahs after the sun had passed its zenith, before Ẓuhr, and he said: ‘It is an hour when the gates of heaven are opened, and I love for a righteous deed to be raised up for me then.’” It was recorded by Aḥmad 3/411 and al-Tirmidhī 2/343; al-Tirmidhī graded it ḥasan, and its chain satisfies the criteria of Muslim.
Note the fine point in his words “before Ẓuhr” following “after the sun has passed its zenith.” Everyone knows that the zenith precedes Ẓuhr, yet he still added that qualifier in order to exclude the Friday Prayer from the general phrase “after the sun has passed its zenith.” Thus the ḥadīth ends up agreeing with the earlier reports that deny any pre-Friday sunnah prayer.