Stick, I'm calling an audible in the name of common sense on this one. A driver may nap or sleep in a CMV without a sleeper and record off duty if the driver is relieved of all responsibilities for the vehicle. The purpose of requiring 10 hours off-duty after 14 hours on-duty is for the driver to have the ability to get at least 8 hours of restorative sleep. The regulations also do not allow a driver to go on duty if ill or fatigued. It would be not be unreasonable to assume that any DOT officer that came across a driver, in a rest area, to call sleeping on the seat as on-duty if the driver could not demonstrate having slept in a place that at least met the minimum requirements required of a sleeper berth. Repeated on-duty and driving periods followed by seat sleeping will surely create a fatigue situation, even for the immortal, bullet proof young drivers, My log falsification may have been overboard, depending how driver records the time.