Standing sleep has limits. Although a horse can doze upright with remarkably little muscular effort, the machinery that supports its weight cannot safely substitute for lying down when rapid eye movement sleep takes hold. Anatomy buys that freedom. Through an arrangement called the stay apparatus, tendons and ligaments stabilize the limbs, allowing rest without the continuous muscular work that standing would otherwise demand.
The catch is neurological. During non-REM sleep, horses can retain enough muscle tone to remain upright, while the stay apparatus reduces the effort required to support their bodies. REM changes the bargain. In this stage, muscle atonia sharply reduces activity in many skeletal muscles, leaving a standing horse unable to reliably maintain its posture despite those supporting structures. Gravity gets its say. Normal REM sleep therefore requires recumbency, either stretched onto the side or resting on the chest with the head supported, so that relaxed muscles need not hold the animal upright.
Comfort is not indulgence. A horse that lacks a sufficiently safe, comfortable place to lie down may obtain standing rest yet miss the REM sleep its body needs. The consequences can show. Repeated drowsiness, buckling knees or collapse can accompany inadequate recumbent sleep, although such signs also warrant veterinary assessment because other disorders can produce similar episodes. Stillness can mislead observers. What looks like an animal sleeping perfectly well on its feet may be one postponing the part of sleep that demands surrender. Even vigilance needs somewhere to rest its head.