Always in the shade and I check him regularly to make sure he's not crying. I'm no advocate of CIO and it's purely because he sleeps well out there not because I won't hear him (as I suspect in times past it may have been the reason)!
I blame my Mum who always asks why he's napping indoors when she comes round and promptly asks if she can wheel him out in his Pram.
Does anyone else do this regularly?