I wonder when first a dictionary will allow “lay” as an intransitive verb, which is the way almost everybody seems to use it now. In fact of course, “lay” requires an object. “I am going to lay down” demands the response, “Yes, but what are you going to lay down?” “Now I lay me down to sleep.” Yet most people in the media seem to believe that “I lay down” is just fine. I think the confusion comes from the (confusing) fact that the past tense of “lie” is “lay” (or “lain”), while the past of “lay” is “laid”. “I lay down” would be correct if you are talking about yesterday: if you are doing it now it’s wrong.

The fact that both “lay” and “lie” have secondary meanings may also be adding to our enthusiasm for confusing them.

Like so many of these language erosions, I always assumed this was a modern phenomenon. But here’s Charles Dickens gently telling off Wilkie Collins in 1862. “There is one slight slip, occurring more than once, which you have not corrected. Magdalen ‘laid down’, and I think someone else ‘laid down’. It is clear that she must either lay herself down, or lie down. To lay is a verb active, and to lie down is a verb neuter. Consequently she lay down, or laid herself down.”

Fowler’s Modern English Usage (1926) points out that the confusion extends over to their usage as nouns, in “the lay of the land” or “the lie of the land” both of which sound all right to us.