Although fighting what may be a losing battle, enough careful writers and speakers distinguish between the verbs lay and lie to make their forms and uses worth our attention.
The verb lay, meaning “to place” or “to put,” is a transitive verb.
A transitive verb is one that takes a direct object. (The prefix trans means “across.” The action of a transitive verb travels across from the subject to the object of the verb.)
Here are some transitive verbs with their objects:
The woman put a rose in her hair. (verb “put” direct object “rose”)
The soldier laid a wreath on the tomb. (verb ” laid ” direct object “wreath”)
The catcher threw the ball to the first baseman. (verb ” threw ” direct object ” ball “)
TIP: In order to identify a direct object, take the verb and ask the question “What?” after it. Ex. Put what? Answer: “rose.” Placed what? Answer: “wreath.”
The verb lie, meaning “to recline,” is an intransitive verb.
An intransitive verb is one that has no object. The action, in a sense, goes nowhere. It stays with the subject.
Here are some intransitive verbs:
The man lies on the green bench.
We play in the park.
The baby slept for three hours.
My sister sings.
You can add any number of adverbs or adverb phrases to an intransitive verb, but it still has no object. Ex. My sister sings in the choir. My sister sings very well. My sister sings flat all the time.
To be sure there is no direct object, take the verb and ask What? after it. Ex. Play what? No answer. “in the park” tells where the playing went on.
Confusion between lay and lie arises from the fact that the past tense of LIE is spelled the same way as the present tense of LAY.
LIE (to recline)
Present: Today I lie in bed until noon.
Past: Yesterday I lay in bed until noon.
Present perfect: I have lain here for hours.
Imperative: Lie down, Bowser!
Present participle: lying
LAY (to put or to place)
Present: Today I lay the table.
Past: Yesterday you laid the table.
Present perfect: I have laid the table every day this week.
Imperative: Lay the table, Charlie!
Present participle: laying
(NOTE: Conjugated like lay is the verb lay with the meaning “to produce an egg.” It can be either transitive or intransitive. The verb lie wih the meaning “to tell an untruth” has the forms lie/lied/(have) lied/lying)
As long as there are editors, publishers, and clients out there who do recognize and observe the difference between lay and lie, it’s probably a good idea for the professional writer to do the same.