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At Shacharit, a right handed Ashkenazi (RHA) wearing tefillin on their left arm puts their head on the right arm. At Mincha, RHAs put our heads on the left arm.

At Shacharit, what should an RHA not wearing tefillin do? Right arm, like everyone else at the time, or left, like is done when not wearing tefillin later?

(Examples of people who wouldn't be wearing tefillin: someone under bar-mitzvah, or who doesn't have tefillin accessible, or is unable to keep themselves 'clean', or are lazy.)

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The Rema in Shulchan Aruch (131:1) writes that at Shacharit (or Mincha;see Mishne Berurah 7) when one wears tefillin, to lean on the right in deference to the tefillin and when not wearing tefillin (e.g. during Mincha or even Shacharit if there is no tefillin on his left arm) he leans on the left side.

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    Basically, the name of the prayer is irrelevant
    – Double AA ♦
    May 20, 2014 at 12:51
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    This is exactly the answer given in my Siddur. An example of this occurs every year on Tisha b'Av (at Mincha which is usually left, it becomes right).
    – Mike
    May 23, 2014 at 2:37

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