The whole purpose behind having casein before bed is to keep your metabolism going and to burn calories. Casein is a slow digesting protein in shake form or in solid form (ex cottage cheese) so you are digesting it all night and it keeps your metabolism elevated. If you have a hard time falling asleep and staying asleep you might try melitonin or ZMA.
My advice would be: If you are trying to cut or maintain eat casein before bed.
If you are trying to bulk: Who cares? Eat anything you want (within limits)