This is what you do when you're really exhausted but don't want to give the impression that you are obeying:
After we tuck the boys in to bed, Emerson gets up about a million times. Sometimes he's got that "I know I'm being naughty grin" and other times he is just wild. Sometimes we'll send him back to bed and he'll give a dramatic "you're ruining all my fun" groan. Really, he's got that groan down pat. All he needs is an eye roll and he's an instant teenager.
The last few nights after we've sent him back to bed (again), we've checked on the boys once it got quiet upstairs. Each time, we've found Emerson laying awake on the floor after wearing himself out...yet refusing to actually get in the bed.