Hello Rav,
Q. I've learned in the past that if I go to sleep and night and then wake up in the middle of the night and want to learn Torah (even just reading silently), then I would need to make a new Birkat HaTorah. A new point I just read and want to clarify is this: If I then go back to sleep (while it is still night), then when I wake up the next morning (after Alot Haschachar), then I would need to make another Birkat HaTorah since a "kavua" sleep at night will always cancel one's Birkat HaTorah bracha. Is this correct? Does it matter how long the nighttime sleep is? If I'm in my bed vs a couch? If I'm in my clothes vs. Pajamas?
A. In question 1339 in regards to someone who wanted to stay up the learn the whole night of Shavuos, but then realized that he is too tired and went to sleep in his bed for an hour, when he comes back to continue learning, does he have to say Birchas Hatorah, we wrote; “Poskim rule that one does not recite Birchas Hatorah, since his intention was only to sleep enough to be able to return to his all-night learning. Therefore there was no “hesech hada’as” or disruption of intent. (Kaf Hachaim 46: 27, et. al.). Horav Shlomo Miller Shlit’a pointed out that at daybreak he should recite the Torah blessing to continue learning until the beginning of davening”.
Aruch Hashulchan (47: 23), differentiates between sleeping before or after midnight. Horav Shlomo Miller Shlit”a follows his opinion.
Therefore in your particular case if you went to sleep with that intention before chatzos and woke up after, you would recite Birchas Hatorah then, and not in the morning. Since the main sleep time is the one before and after midnight, the second period would be seen as sleeping during the day.
We added on that question that “Horav Shlomo Miller’s Shlit’a opinion is that in cases where there is some doubt of having to recite the Torah blessing, which according to many Poskim is of Biblical origin, one may recite it without pronouncing Hashem’s name. He would thus comply at least on the Biblical level, the requirement of Birchas Hatorah.”
Rabbi A. Bartfeld as revised by Horav Shlomo Miller Shlit’a