Write around them: resting my case on lay vs. lie
There appear to be a set of language rules that to most people simply sound wrong when you use the right word. Who and whom is chief among them, as few people, despite the efforts of their seventh grade language arts teacher, know when to use which one. Lay and lie and their various forms are another pair of such words.
For the record, lay/laid/laying means to set down (I laid my exhausted child in her bed.). It always requires an object or something that can be set down. Lie/lain/lying and the past tense lay means to recline, as in I had lain on the beach for several hours. It can’t take an object.
The use of the archaic-sounding lain and the confusing use of lay as a past tense version of lie demonstrates that, as is the case with all languages, the rules speakers and writers use regarding these words are evolving. Indeed, most people will tell you that lay down is correct (All I want to do at the end of the day is lay down.) when it technically isn’t.
Because using lay/lie correctly often sounds wrong and because there are grammar police out there who will flag you for not using the words correctly, the simple solution for authors is to write around the problem.
Simply put, use set or place rather than lay/laid/laying and recline for lie/lain/lying. Or even better, as set, place and recline are dull verbs, why not rewrite the sentence so that more exciting action occurs in it?
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