Hard Tefillin Case

Question: I keep my tefillin in a hard, flask-style case. Recently, our teacher told us that these are not ideal as the tefillin shel yad is sitting on top of the tefillin shel rosh. Do I need to switch to a classical tefillin bag?

Answer: The Gemara (Menachos 36a) teaches that when putting on one’s tefillin, the tefillin shel yad should be placed on before the tefillin shel rosh. Since the Torah refers to the tefillin shel rosh as totafos, in the plural form, one should ensure that the tefillin shel yad is already worn. For this reason, the tefillin shel rosh is also removed first.

When using a hard case, one would typically place the tefillin shel rosh in first, with the tefillin shel yad on top. The Gemara (Menachos 34b) notes that the tefillin shel rosh has greater kedusha than the tefillin shel yad (see Rashi). Placing the tefillin shel yad in first may seem like a solution, but this can create difficulties when removing the tefillin the next time, since the principle of ein maavirin al hamitzvos applies to tefillin (Yoma 33a).

The Bach (OC 28:2) and Taz (OC 28:11) write that ideally one should use a narrow tefillin bag, placing the tefillin shel yad above the tefillin shel rosh, thereby preventing the tefillin shel rosh from being removed first by mistake. However, the Magen Avraham (28:4) and Mishna Berura (28:7) argue that one must avoid placing the tefillin shel yad above the tefillin shel rosh. Rather, one should store the tefillin side by side in a bag, with the tefillin shel yad positioned closer to the opening.

One practical solution is to store the tefillin case horizontally rather than standing upright. This ensures that the tefillin shel yad is not placed above the tefillin shel rosh and helps prevent the tefillin shel rosh from being removed first by mistake.

In conclusion, storing a hard case horizontally may even be preferable to a classical tefillin bag, as it ensures the tefillin shel yad and tefillin shel rosh are always stored correctly.