The Status of Berachot Recited After Arbit But Before Sundown

The requirement to recite 100 Berachot each day refers to the period between sundown and sundown the following day. Hence, the Berachot recited in the evening count toward the next day's total with respect to this obligation. This gives rise to a number of interesting questions in situations where it is unclear how to classify a certain time-period. One such question involves Friday evenings in the summer, when many people recite Arbit and accept Shabbat early, before sundown (after the point of "Pelag Ha'minha"). Do those Berachot recited at Arbit – and the Berachot recited at the meal before sundown – count toward Friday's total of Berachot, since the sun has yet to set? Or, since one has accepted Shabbat, do these Berachot count toward the next day's number? Hacham Ovadia Yosef answered this question based on a ruling of the Taz (Rav David Segal, Poland, 1586-1667) regarding one who prayed Arbit early, before sundown, on the night of Shemini Aseret. In the case of Shemini Aseret, the day before this Yom Tob is Hoshana Rabba, the final day of Sukkot. Therefore, when one accepts Yom Tob early, before sundown, he faces the question of whether the time that remains until sundown is considered Sukkot or Shemini Aseret. In Israel, where people do not eat in the Sukka on Shemini Aseret, this question determines whether the individual must eat in the Sukka, because the sun has yet to set on the final day of Sukkot, or if he may eat inside his home, since he has already accepted Shemini Aseret, such that Sukkot has already ended. The Taz ruled that once the person recited Arbit, he has ushered in the new Halachic day, and so in this case, the individual does not need to eat in the Sukka. Hacham Ovadia accepts this ruling, and thus concludes that by the same token, one who accepts Shabbat early has transitioned to the next day, Shabbat, and all the Berachot he recites count toward Shabbat's total of Berachot, even though the sun is still out. This principle applies in the converse in the case of a Se'uda Shelishit meal that is eaten late in the afternoon on Shabbat, and continues after dark. Since the person has in effect extended Shabbat past sunset, the Berachot of Birkat Ha'mazon that he recites after dark still count toward Shabbat's total, as this period is still considered Shabbat. (However, if one recites Arbit during Se'uda Shelishit, then he has begun the new day, and thus the Berachot he recites subsequently during Birkat Ha'mazon will count toward Sunday's total.) This becomes especially important when we consider the difficulty entailed in reaching the total of 100 Berachot on Shabbat, when the Amida consists of only seven blessings (as opposed to the weekday Amida, which consists of 19 Berachot). Rav Shlomo Zalman Auerbach (Jerusalem, 1910-1995) disagreed. He maintained that the obligation of 100 daily Berachot refers to the period from sunset to sunset, even if one accepts Shabbat before sunset or extends Shabbat past sunset. In his view, all the Berachot recited before sunset count toward the previous day's total, whereas the Berachot recited after sunset count toward the new day's total. (This poses a challenge for those who accept Shabbat early, as the Berachot of Arbit are not counted toward the required 100 Berachot of Shabbat.) In any event, we follow Hacham Ovadia's opinion, that if one accepts Shabbat early or extends Shabbat past sundown, the Berachot count toward Shabbat's total. Does this apply also on weekdays? If a person recites Arbit before sundown on a weekday during the summer, do the Berachot recited at Arbit, and Berachot recited subsequently, before sunset, count toward that day's number of Berachot, or the next day's total? This question seems to hinge on a debate among the Rishonim concerning the case of a woman who performed the Hefsek Tahara inspection (which establishes the cessation of bleeding, so she can begin the "seven clean days") after reciting Arbit. This inspection must be performed during the day, and the question thus becomes whether it is valid if was done before sundown but after the woman recited Arbit. The Terumat Ha'deshen (Rav Yisrael Isserlein, 1390-1460) maintained that once a person recites Arbit, even before sundown, he has begun Halachic nighttime, and thus the woman in this case has already begun the night, when it is too late to perform the Hefsek Tahara. By contrast, the Maharil (Rav Yaakob Moelin, Germany, 1365-1427) ruled that the recitation of Arbit does not affect the status of the time that remains until sunset, and it is still considered daytime. Therefore, the woman may still perform a Hefsek Tahara even after reciting Arbit, as long as the sun has not set. Hacham Ovadia Yosef, in his Taharat Ha'bayit, follows the Maharil's position, that a woman may perform a Hefsek Tahara after she recited Arbit if the sun has not set. We would thus seemingly assume that with regard to the obligation of 100 daily Berachot, too, reciting Arbit before sundown on a weekday does not mark the onset of nighttime, and thus the Berachot recited count toward that day's number of Berachot. A similar question arises in the case of a person who, for whatever reason, did not put on Tefillin all day, and recited Arbit before sundown. The Shulhan Aruch – seemingly following the opinion of the Terumat Ha'deshen – rules that this individual can no longer put on Tefillin, because by reciting Arbit he has begun the nighttime, when Tefillin are not worn. Hacham Ovadia, however, writes that the person can still put on Tefillin, since the sun had not set. Returning to the issue of the 100 daily Berachot, it would seem that according to the Shulhan Aruch, the Berachot recited during Arbit before sundown count toward the next day's total, whereas according to Hacham Ovadia, they count toward the previous day's total. Given the different opinions, this issue remains unresolved, and we cannot ascertain the status of Berachot recited after a person recited Arbit before sundown. Summary: If a person begins Shabbat early, before sundown, the Berachot he recites during Arbit and after Arbit count toward his number of blessings recited on Shabbat with respect to the obligation of 100 daily blessings, even though the sun has not yet. Likewise, if one extends Se'uda Shelishit past sundown, the Berachot of Birkat Ha'mazon count towards Shabbat's total, since he has yet to end Shabbat. On weekdays, however, if one recites Arbit before sundown, it is unclear whether those Berachot – and the Berachot recited after Arbit, before sundown – count toward the previous day's total, or the next day's total.