EDIT: I probably should have added this in the beginning, sorry I didn't.
Penny had recently started sleeping naked after the events of It's Hot Outside. After Penny reacted the way she did in that, they had a whole talk about being naked. Penny realized she only acted like that because that's just how people act on TV. She didn't actually care. Judge told her that when you live with someone, moments like that are going to happen where you accidentally see someone naked, or in the bathroom, and instead of freaking out about it, they should just accept it as a part of life. (In later comics, this has helped in some ways, but backfired in others)
But for this comic, She had stayed up late the previous night because it was a Friday night, and woke up early for cartoons, so she was tired and groggy, and while she remembered to put her hair ties on, she forgot that she was naked.
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