I've used my Xr many times while laying in the bed and its always unlocked without issue. However, unlike the new iPad Pro it doesn't work if you turn the phone to landscape mode and attempt to unlock it. If I am using GPS/Maps the screen never turns off so therefore I have no need to unlock it in landscape mode. However, if for some reason you maneuver out of GPS/Maps then it will go dark if not used for whatever your time-out is set for. That would require an unlock and you would have to turn the phone back vertical to unlock it.