The surface of your body can have another temperature than the inner part because it is in contact with the surrounding air. Oral, ear, armpit, rectal, skin etc all have slightly different temperatures even if you measure them at the same time. You need to compensate for the difference to get the core temperature.
Are you asking about the problems of measuring in an ear that was toward the pillow when lying down on the side?
The pillow will work like insulation that rescues air flow and heat transportation. So your ear toward the pillow will be slightly warmer than the other ear for this reason. So if you first measure the temperature before you lay down and then after it can the reading can increase even if the core body temperature has stayed the same, the ear got a bit warmer
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