The Manhattan Criminal Courts Building has rules but none of them say you can’t close your eyes or sleep during your trial.
“As his lawyer Todd Blanche argued about an email he wanted to enter into evidence, Trump sat very still, stony-faced. He often closed his eyes when his lawyers and the prosecutors approached the bench for one of countless conferences they held out of the jury’s earshot. And he closed his eyes as Cohen talked about Daniels, with only the occasional adjustment of his collar or shift in his posture implying that he was actually awake.”
Jess Bidgood, The New York Times: Trump’s Eyes Wide Shut Strategy