ARTICLE
25 April 2025

Lie (Lay) Down!

MH
Markowitz Herbold PC

Contributor

Markowitz Herbold is a litigation law firm that tries high-stakes business disputes for individuals, companies and state, local and regional governments, to juries, judges and arbitrators. We are known by our peers for resolving complicated and challenging cases.

The firm is based in Portland, Oregon, and our lawyers practice before state and federal trial courts in the Northwest and across the country.

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This week we discuss the use of "lie" versus "lay," a topic that sucks us into the realm of transitive verbs (which require an object to express a complete thought)...
United States Food, Drugs, Healthcare, Life Sciences

This week we discuss the use of "lie" versus "lay," a topic that sucks us into the realm of transitive verbs (which require an object to express a complete thought) and intransitive verbs (which don't). Lay is a transitive verb, so it should be used with a direct object, e.g., "Lay your cards on the table." ("Your cards" is the direct object of the verb "lay.") Lie is an intransitive verb and does not require a direct object, e.g., "I need to lie down."

Because that might not make a lot of sense, here's another way to think about it. "Lay" means to place or put; so you always "lay" something, e.g.,

  • Lay your book on the counter. ("Book" is the direct object of the verb "lay.")
  • Lay your hat over there. ("Hat" is the direct object of "lay.")
  • Now I lay me down to sleep. ("Me" is the direct object of "lay.")

"Lie" means to rest on a surface—it doesn't act on anyone or anything else, e.g.,

  • Lie down on the bed.
  • My pencil lies next to my toy Ferrari.

Got it? Good, because now it's time to talk about the past tense and past participle of lay and lie. (Past participles are adjectives formed from verbs.) Both of these verbs are irregular, and super confusing. So to help you keep track, here's a chart:

VERB Present Tense Past Tense Past Participle

Lay Lay Laid Laid

Lie Lie Lay(!) Lain

As you can see, the present tense of "lay" is the past tense of "lie." (Wait . . . what?) That's one reason that English is such a hard language to learn—crazy irregular verbs. Anyway, here are examples of the past tense and past participle of "lay":

  • Yesterday, I laid my cards on the table—and lost.
  • I have laid my draft brief on your desk.
  • Last night, I laid me down to sleep.

Here are examples of the past tense and past participle of "lie":

  • Last night, the cat lay in wait for her food.
  • The cat has lain in wait for her food for hours . . . and hours . . . and hours. (Where are her people?)

That is all for now ...

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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