New York may never sleep, as the song says, but some writers and editors there do. Bick Satterfield submits evidence from The New Yorker: "Laying there on the ground, next to the sheet, was a banana peel." No, the banana peel was lying there on the ground. Satterfield says that many people, too many actually, still don't understand the uses of lie and lay. He's right.
About the same time I received Satterfield's letter — yes, it was a letter, not an e-mail — I saw in The Week magazine a blurb about a movie: "The American — George Clooney plays a brooding assassin trying to lay low in Italy in this atmospheric suspense thriller." Really, George was trying to lie low. I believe the home office of The Week is in London; you'd expect journalists there to know the Queen's English too. This kind of malfeasance is enough to make an assassin brood. (Though I have to admit that between brooding assassins and shooting assassins, I much prefer the former.)
The verbs lie and lay are not interchangeable. Lay means "to cause something to lie; put," as in "Lay that pistol down, Babe, lay that pistol down." To lie is "to be in, or move into, a reclining position, or on or onto a flat surface," as in, "Just lie there and brood, why don't you?" The past tense of lie is lay — "He lay down" — which may help confuse matters. The past participle of lie is lain — "The banana peel has lain there for days." The past tense and past participle of lay are both laid. "She laid her pistol down" and "she has laid her pistol down."
(Speaking of "the city that never sleeps," I wish somebody would take up her pistol and shoot those responsible for the Belmont's discarding "The Sidewalks of New York" and adopting "New York, New York" as the race's official song. Class replaced by cheese. Is there no taste left, Honey Boo Boo?)
"Mills demonstrated his legislative acumen when lining up support for the proposed Beaver Dam and Lake ... Mills advised Congressman Jim Trimble not to talk to the House Public Works Committee chairman, Clifford Davis of Memphis, when Davis was drinking. Trimble waited for weeks on end, then finally tried his luck. Just as Mills expected, Davis balled out Trimble and threw him out of his office."