dog on top of a cat

I saw many people use 'laying' like

Laying on top of his throw-up.

Woman Laying On Top Of Man.

, but shouldn't they be written with "lying", rather than "laying"? And if they want to stick to "laying", shouldn't they phrase like as follows?

1.Laying himself on top of his throw-up.

2.Woman Laying Herself On Top Of Man.


In formal usage, yes, these should be "lying".

In colloquial usage, the distinction between "lie" and "lay" is gradually disappearing. For some speakers, they're interchangeable.

(You should still learn them both, because for most speakers they're still different, especially in formal usage.)

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  • From Garner's Modern American Usage 3rd Ed: lie (= to recline, be situated) is intransitive—it can’t take a direct object (he lies on his bed). But lay (= to put down, arrange) is always transitive—it needs a direct object. Because lie is intransitive, it has only an active voice (lie down for a while). And because lay is transitive, it may be either active (he laid the blanket over her) or passive.To use lay without a direct object, in the sense of lie, is nonstandard (I want to lay down) (he was laying in the sun). – Michael Login Apr 28 '19 at 11:35
  • But this error is very common in speech—from the illiterate to the highly educated. In fact, some commentators believe that people make this mistake more often than any other in the English language. Others claim that it’s no longer a mistake—or even that it never was. But make no mistake: using these verbs correctly is a mark of refinement. – Michael Login Apr 28 '19 at 11:35
  • Yes, there's some prejudice against speakers who merge "lie" and "lay". That's why students of English should learn the difference. But it's not usually a mistake, just dialectal variation. – Anonymous Apr 28 '19 at 14:12

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