Q. A person who came to shul among the first ten, and upon arrival fell asleep at a shtender, and when he woke up at the beginning of davening, the beis medrash was full – does he get credit for being among the first ten, even though at the time he was asleep, he did not count for the minyan according to some opinions?
A. Shulchan Aruch (O. H. 55: 6) rules that one sleeping can be counted for a minyan. Mishna Berura (ibid. 34) quotes the Taz and Pri Chodosh dissenting opinions than one asleep is considered as similar to a “shote” (deranged) and cannot be included. However, he maintains that although on the onset he should be wakened, after the fact he counts for the minyan.
Biur Halocho (ibid.) mentions to be stringent on the repetition of the amida, since it could entail reciting brochos in vain.
Piskei Teshuvos (ibid. 12) mentions additional stringent opinions that the inclusion may depend on the position of the sleeper and whether his face is covered, or not.
Horav Shlomo Miller’s Shlit’a opinion is that being credited as being among the first ten would depend on the opinions above mentioned. However, the Rov maintains that for many halachos such as gittin etc. the sleeping are not considered shotim.
Rabbi A. Bartfeld as revised by Horav Shlomo Miller Shlit’a.