This goal has the following fine print specified by rperce:
If you're on your phone late at night, check the time. In the worst case, you must check the time when you turn the screen off and go to the always-on lockscreen. If it's after 1am, turn the phone on and put a 0 datapoint on this goal. If, on the next day, you're reasonably sure you were in bed before 1am and didn't use your phone, go ahead and get the +1.