How to use lay and lie in your writing


Did you lie in bed last night contemplating the meaning of life, the universe and everything? Or did you lay there? Are you laying on the couch now while you read this on your electronic device of choice? Or are you lying there? So many big questions, so little time to find out the answers. Here’s my guide to all things laying, lying and gently reclining. Okay, maybe not that last thing.

Lay and lie are both irregular verbs

Let’s start with the basics. In the sentences we are talking about here, lay and lie are both irregular verbs. An irregular verb is one where the past tense doesn’t follow the usual -d, -ed or -ied spelling pattern of regular verbs like thrive/thrived, kiss/kissed and cry/cried. There are heaps of irregular verbs in English and many of them are among the most commonly used words: think/thought, drink/drank, go/went, run/ran, know/knew … the list goes on.

Lie can also be a noun, of course, as in ‘I told a big fat lie today’, but that’s not the kind of lie we are interested in here. And there lies part of the dilemma (pun totally intended). I think sometimes we’re hesitant to use lie and lying in the ‘reclining’ sense because we worry about possible confusion with the big whopper fib kind of lie.

But back to verbs: the main difference, in grammatical terms, between lay and lie is that lay is a transitive verb, while lie is an intransitive verb. What the heck does that mean? I hear you ask. Allow me to elaborate.

Lay is a transitive verb

The verb to lay means to put or place something or someone down. It’s a transitive verb, which means it requires a direct object. A direct object receives the action of the verb. So when you use the word lay, it needs to have a direct object to act upon. Consider these examples:

  1. Our Australorp chickens lay their eggs on a soft bed of straw in their homemade chicken coop.
  2. The brilliant professor laid her book on the desk before glaring at me over her glasses.
  3. Gregory carefully laid his sleeping son on the bed.

In each of these examples, a direct object comes after the relevant verb form of to lay: their eggs, her book and his sleeping son. So lay needs to be followed by something or someone.

Lie is an intransitive verb

The verb to lie, on the other hand, is an intransitive verb meaning to rest or recline. It doesn’t need a direct object after it. Consider these examples:

  1. Our clothes are covered in fur because Pickle, our crazy tabby cat, loves to lie on the clean washing every chance she gets.
  2. After hiking 23 km to Mount Feathertop yesterday, I spent all day today lying on the lounge like a lazy lizard.
  3. The gently lapping waves lulled Lucy to sleep as she lay on the lilo in the lake. (Okay, I’ve got a thing for alliteration.)

What’s that? You noticed the word lay in number 3? Oh-oh. Yep, it’s confusing because besides being a separate verb in its own right, lay is also the simple past tense of the verb to lie. Let’s have a closer look at the different verb forms of lay and lie.

Choosing the correct verb form of lay or lie

Once you’ve decided whether you’re talking about placing something down (to lay) or reclining (to lie), you need to choose the correct verb form to use, depending on the tense of your sentence. Here’s a table that lays it all out. (Have I used lays correctly there? Is it followed by a direct object? Yep – it.) 

Lay, lie, laying, lying verb forms

So when do you use each of these verb forms?

Simple present: lay/lays and lie/lies

Use the simple present form of lay or lie when you’re writing about an action that happens consistently or is happening right now:

My cat usually lays any wildlife she catches right at our front door. Isn’t that nice of her? [The cat’s action of placing the wildlife at the front door happens consistently.]


As the sunlight streams through the leaves of the rainforest canopy, Philippe lies asleep on the forest floor below. [Philippe’s action of resting or sleeping is happening right now.]

Present participle: laying and lying

Use the present participle form of lay or lie when you’re writing about an action that was happening in the past, is happening right now or is happening consistently:

While I was distracted by the huge spider on the wall, my cat was carefully laying a dead mouse at my feet. [The cat’s action of placing a dead mouse at my feet was happening in the past.]


Philippe is lying on the forest floor while he contemplates the meaning of life. [Philippe’s action of reclining on the forest floor is happening right now.]


Stop leaving your dirty clothes lying on the bathroom floor; it’s driving me crazy! [Your action of leaving dirty clothes resting on the floor is happening consistently.]

Note that you could also write the last sentence using lay if you treated the dirty clothes as the direct object of the verb:

Stop laying your dirty clothes on the bathroom floor; it’s driving me crazy!

Simple past: laid and lay

Use the simple past form of lay or lie when you’re writing about an action completed in the past:

Last week my cat laid her catch, a gecko, under the dining table. [The cat’s action of placing down her catch happened last week.]


Philippe lay asleep for more than an hour before he awoke to drops of rain sploshing on his face and scrambled to his feet. [Philippe’s action of resting has now been completed.]

Past participle: laid and lain

Use the past participle form of lay or lie when one or more auxiliary verbs help form the tense (auxiliary verbs are ‘helping verbs’ used with the main verb):

My cat had just laid her latest catch, a bloodied mouse, on the doorstep when my date arrived to pick me up. What timing! [The cat had placed the mouse on the doorstep.]


The forest was so beautiful Philippe could have lain there all day enjoying the tranquillity. [Philippe could have rested there all day.]

How to choose between lay and lie

If you’re bamboozled by all this grammatical jargon about transitive and intransitive verbs, direct and indirect objects and past and present participles, here’s my simple 3-step process for choosing the correct form of lay or lie to use in your writing:

  1. Decide whether your intended meaning is to place something or someone down or to rest, recline or sleep.
  2. If your meaning is to place something or someone down, write your sentence using the verb to lay. If your meaning is to rest, recline or sleep, write your sentence using the verb to lie. Use this simple mnemonic to help you remember: lay = pLAce; lie = recLIne.
  3. Check you’ve done it correctly by replacing lay/laying/laid/laid with place/placing/placed/placed, respectively, or by replacing lie/lying/lay/lain with rest/resting/rested/rested, respectively. Does it still make sense?

And to help you remember that the past tense of lay is laid (rather than lain), remember that lay needs a direct object – and direct starts with the letter D!

So is it lying in bed or laying in bed?

Let’s check those questions I asked at the start: Did you lie in bed last night or did you lay there? Are you laying on the couch now or are you lying there? Well, we’re not talking about placing something down; there is no direct object. And you’re not placing in bed or on the couch; you’re reclining there. So the verb you need is lie. Here are sentence examples using the 4 different verb forms:

  1. Simple present: I often lie awake at night contemplating the meaning of life.
  2. Present participle: When I’m lying awake at 3 o’clock in the morning, I feel compelled to contemplate the meaning of life.
  3. Simple past: Last night I lay awake for 3 hours after my cat meowed at the door with a dead mouse.
  4. Past participle: I have lain awake at night for hours over the past few weeks, contemplating the meaning of life.

The only correct way to use the verb to lay in the sleeping or reclining sense is to add a direct object, like in the old children’s prayer, ‘Now I Lay Me Down to Sleep’. But what about the lyrics of the Bob Dylan song, ‘Lay Lady Lay’? Well, that’s poetic licence for you. Lie doesn’t rhyme so well with stay, now, does it? Anyway, I ain’t gonna argue with a Nobel Prize winner.

Need an editor to check whether you’ve mixed up your lays and lies? Contact me now to discuss your writing project.

PS. My cat is far too old now to catch and lay dead creatures at my feet, or anywhere for that matter. But I do sometimes encounter scary large huntsman spiders in the house. And if I’m lying on the couch at the time, it’s a sure way to get me up from my reclining position!