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Dizziness is generally relieved, not exacerbated, by lying down. However, if you have a condition called benign paroxysmal positional vertigo, you are going to battle dizziness while lying in bed. (BananaStock/BananaStock/Getty Images).
To be honest, I think the most common cause of dizziness while lying down is alcohol. That's the only time I've experienced it, anyway. It happens if I've had a couple too many and I usually only notice it when I'm trying to sleep. It feels like the room is spinning.