Even for speakers who feel solid about the distinction between "lie" and "lay," they may lose that distinction when "low" is added to the mix.
Recently, one of Professor Anne Curzan's colleagues texted her to say they wouldn't be attending a meeting. They said they were trying to finish an article and would instead be "laying low."
That last part jogged Curzan's memory.
A few years ago, Curzan was texting a friend to let them know she planned to "lay low" instead of coming to dinner. She was about to hit "send," when she started second-guessing her wording -- should it be "lay low" or "lie low"?
"I thought that 'lie low' would be right, but 'lay low' sounded better," Curzan says. "It's been on my mind ever since."
Historically, "lie" is the intransitive verb. That means it doesn't take an object. For example, "I am lying on the couch" or "The cat is lying in the sun."
On the other hand, "lay" is the transitive verb and the causative of "lie." In other words, you're making something lie, as in "I'm laying down the placemats."
We have several century's worth of usage that shows these two verbs being used interchangeably in some situations. Probably the main source of confusion is that "lay" is both the past tense of "lie" and the present tense of "lay," while "laid" is the past tense of "lay."
Just to make things even more confusing, "lay" also has a reflexive construction, as in "I lay myself down" or "I lay me down." In these examples "myself" and "me" are objects, but this construction has led to idiomatic usage, such as "I'm going to lay down for a few minutes."
That brings us back to "lay low" vs. "lie low." If "lay low" sounds perfectly natural to you, that's because it's actually over taking "lie low" as the common construction in both speech and written usage. Curzan thinks "lay low" may even be the clear winner at this point.
Keep an eye on "lay" and "lie." There's still a lot variation in usage, but as we've been known to say, language is constantly changing.