two main reasons.
First, in most stages of sleep our brain does not send “movement” signals to our body. Without your brain telling it to move the body remains still.
Second, in REM sleep the brain does send movement signals to the body, but the body is in a “paralyzed” state. This paralyzed state is only during REM sleep.
Most people who “toss and turn” when they sleep are actually waking up briefly to move, and just do not remember this because they were awake for such a short time. Your body does not know “not to fall out of bed” during these short awakenings, and it is during these movements that people can fall out of bed
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