Why it matters: Trump, the first former president to ever stand criminal trial and with several more cases pending, has made attacks on President Biden's age and energy levels — such as "Sleepy Joe" — central to his political attacks in an attempt to contrast with his own vitality.
State of play: Trump appeared to doze off a few times with his mouth hanging open and his head drooping down, the New York Times reports from the court room.
Trump's lead counsel, Todd Blanche, passed him notes for several minutes before he "appeared to jolt awake and notice them," per the Times.
Zoom out: Trumppreviously jabbed his 2024 rival when he appeared to fall asleep at a 2021 conference overseas.
"Nobody that has true enthusiasm and belief in a subject will ever fall asleep!" Trump wrote in an email to supporters at the time.