Many perceive eating as the primary use for the sukkah and relegate sleeping there to the particularly scrupulous (cf. Rema, O.C. 639:2). This perspective is odd, given that Sukkot has more stringent rules governing sleeping than eating. Only full meals must be eaten in the sukkah, snacks need not. No such dispensation exists for sleeping; even the slightest doze is forbidden outside the sukkah (Sukkah 26a).
Sleeping in the sukkah was not a significant hardship in the Jews’ natural habitat – Eretz Yisrael (and surrounding areas), where weather on Sukkot is usually pleasant. When Jews began moving northward into Europe, many found that the colder climate made sleeping in the sukkah unbearable or potentially even a health risk.(1) Since ill people and even those who are in serious discomfort (mitzta‘er) are exempt from the sukkah (Sukkah 25b-26a), poskim justified the widespread laxity about sleeping in the sukkah in Europe (Mordechai, Sukkah 739). Since it is also much rainier on Sukkot in northern climes than in Eretz Yisrael, some authorities bolstered the exemption by maintaining that it was unreasonable to expect people to sleep soundly under constant threat of a midnight shower (Meiri, Sukkah 26a).
The Rema, however, is unconvinced by weather-based excuses (Darkei Moshe, O.C. 639:3). He maintains that it is generally not sufficiently cold even in Europe to constitute a blanket exemption (pun intended) from sleeping in the sukkah. After all, the way one treats dwelling in the sukkah should be similar to the standard one applies to one’s home (“teishvu ke’ein taduru,” Sukkah 28b). Barring truly extreme frigidity, one would not leave home, even if unheated, to sleep elsewhere; one would simply use warmer bedclothes. Therefore, argues the Rema, one should treat the sukkah similarly and simply bring extra comforters if one is chilly.
The Rema instead suggests that the general European reluctance to sleep in the sukkah is due to people’s reliance on communal sukkot rather than each household building their own. The normal and proper manner of dwelling is for husband and wife to sleep in the same room (even if the wife is a niddah, cf. Eiruvin 63b), a situation obviously precluded in a communal sukkah, in which sleeping arrangements are necessarily single-sex. Splitting married couples is not teishvu ke’ein taduru. Indeed, the Rema notes that the Gemara itself invokes this concept to suggest that Kohanim are exempt from sukkah because their wives are not present when they serve at the Beit HaMikdash (Arachin 3b).
Although the Rema relies on this argument in practice (O.C. 639:2), he acknowledges the difficulty with it and later poskim reject it outright. The Vilna Gaon points out that the conclusion of the very Gemara that the Rema cites actually disproves his point (Bei’ur HaGra ad loc., citing Rashi and Tosafot in Arachin). The Magen Avraham notes, based on a different Gemara, that if the principle of teishvu ke’ein taduru is taken to refer to married couples sleeping together, it would in fact obligate women in the mitzvah of sukkah, not exempt men (639:8 citing Sukkah 28b).
The Magen Avraham does, however, suggest that a man may be genuinely mitzta‘er if forced to sleep separately from his wife. The Taz redirects the focus to the woman, noting that husbands have a special requirement to gladden their wives on holidays (Pesachim 109a); this indicates that it is particularly inappropriate for a husband to cause his wife distress by sleeping apart from her during a festival (O.C. 639:9, this would be all the more applicable during the first year of marriage).(2)
Rabbi Yaakov Ettlinger disagrees with the Taz, noting that we only find an explicit obligation for husbands to gladden their wives on holidays via material gifts, not their physical presence (Bikkurei Yaakov ad loc.). He further expresses confidence than any G-d-fearing Jewess would surely prefer that her husband perform a mitzvah by sleeping in the sukkah even at the expense of her personal comfort.
Of course, everyone would agree that the ideal is for a couple to arrange for a sufficiently private sukkah to facilitate their sleeping together (in which case, marital relations are also permitted). Although few households entertain the possibility of erecting more than one sukkah, those who have a sufficiently large and well-configured property should strongly consider providing married couples with a separate sukkah (assuming the wife is willing to sleep outside despite being entirely exempt from the sukkah).
Besides being disputed, the climate-related and couples-related exemptions from sleeping in the sukkah are of limited applicability. The latter, of course, are of no use to single men, and the former are irrelevant in places with mild weather on Sukkot (such as, arguably, New York). Are there any other considerations for leniency?
Rabbeinu Manoach, a 13th century commentator on Rambam’s Mishneh Torah, suggests that the reason for not sleeping in the sukkah is far more general: since people are more sensitive than in Talmudic times, sleeping in the more exposed environment of the sukkah is not considered normal living (Hilchot Sukkah 6:6). Nowadays, many people are certainly even finickier than in Rabbeinu Manoach’s time and find it difficult to sleep with light and noise. Those of us who live in Manhattan have it particularly bad; sukkot are usually communal and often built close to busy streets, a combination that makes sleeping there quite a challenge. (Rabbeinu Manoach also suggests that people are disturbed by the possibility of their home being burgled while they are out in the sukkah. This is not usually a concern nowadays, but some people are anxious about their physical safety while sleeping outdoors in certain locales.)
Yet another general reason to excuse those who do not sleep in the sukkah is put forth by Rabbi Shneur Zalman of Liadi: Most people do not have a separate sukkah for sleeping and would need to constantly rearrange the furnishings in the sukkah from eating mode to sleeping mode and back again (Shulchan Aruch HaRav 639:8). In one’s home, one would not tolerate the shlep of removing the dining furniture and setting up the sleeping furniture every time one wished to doze, so one is exempt from doing so in the sukkah as well. Of course, rather than exempting themselves from sleeping in a sukkah, it would behoove those who have expansive properties to consider building a separate sukkah for sleeping to address the logic of the Ba‘al Hatanya.(3)
We have seen that any blanket excuse not to sleep in the sukkah is arguable. Rather, each person must be honest with himself as to whether he is truly discomfited by sleeping in the sukkah to the extent that he is legitimately exempt. One must take into consideration the particular circumstances and each individual’s disposition. For example, a person might manage sleeping in the sukkah in the suburbs but not in the city, or for daytime naps but not nighttime slumber or vice versa.
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- The same logic may apply, in the other climatic direction, to newer Jewish population centers such as South Florida. Note further that this article does not address the opinion of some poskim that a sukkah is invalid if built in a manner that one is only comfortable eating there but not sleeping (Yereim 421; Rema, O.C. 640:4).
- Some Acharonim imply that a husband may certainly spend the entire night at home when the couple has relations (Mishnah Berurah 639:18). It is questionable whether this dispensation can be used nightly, since the Mishnah Berurah’s language of “one should not neglect the prescribed conjugal interval and the night of immersion” seems to limit it to occasions that relations are specifically ordained (even though additional times could also be a mitzvah under the correct conditions).
- Lubavitch chasidim nowadays do not follow the ruling of the Alter Rebbe – even if a separate, comfortable sukkah for sleeping is available, they specifically refrain from sleeping there due to the structure’s intense holiness (search Chabad.org for details). This is obviously a very novel approach.