A Word, Please: As Ginsburg lay in state, news reports flubbed the past tense of ‘lie’

Capitol Hill staffers pay their respects as the late Justice Ruth Bader Ginsburg lies in state.
Capitol Hill staffers pay their respects as the late Justice Ruth Bader Ginsburg lies in state at National Statuary Hall in the U.S. Capitol on Sept. 25 in Washington, DC. June Casagrande points out that news media used erroneous words for the past tense of “lie.”
(Greg Nash / Getty Images)

When plans were announced for late Supreme Court Justice Ruth Bader Ginsburg to lie in state at the Capitol, no one seemed to struggle with the verb. But after the fact, editors and social media managers stumbled.

“Ruth Bader Ginsburg’s trainer of 21 years, Bryant Johnson, paid tribute to her with a set of push-ups as she laid in state at the Capitol on Friday,” National Public Radio announced in a Facebook post.

NBC News tweeted: “The flag-draped casket of Justice Ruth Bader Ginsburg lied in state at the US Capitol.”

For news folks, those are bad errors. Unlike casual users who have a lot of leeway in how they use “lay” and “lie,” news agencies are supposed to follow the strict guidelines for these words.

Present and future tenses don’t seem to cause too much confusion, but past tense forms trip people up — even pros. So for anyone who wants to master “lay” and “lie,” here’s a refresher.

Lay is a transitive verb, which means it takes an object. You don’t just lay. You lay something. For example, a rug in “I’m going to lay this rug on the floor.”

Lie is intransitive. It does not take an object. “I’m going to lie down.” You don’t lie a rug on the floor. You yourself lie.

Both these verbs are irregular, meaning they don’t follow the formula regular verbs use to express something that happened in the past. The regular verb “walk,” for instance, forms both its past tense and its past participle by adding “ed.” That’s the formula for most regular verbs: Today I walk. Yesterday I walked. In the past I have walked.

Don’t let the term “participle” scare you. The past participle is just the one that goes with some form of “have”: I have walked. He had walked.

Irregular verbs defy this pattern. Today I begin. Yesterday I began. In the past I have begun. Today I break. Yesterday I broke. In the past I have broken.

Some irregular verbs use the same form for both the past tense and the past participle. Today I buy. Yesterday I bought. In the past I have bought. Today I cling. Yesterday I clung. In the past I have clung.

Still others have past forms that are identical to their present tense. Today I cut. Yesterday I cut. In the past I have cut. Today I let. Yesterday I let. In the past I have let.

The most irregular verb of all is “be,” which goes off script not just with its past-tense forms but with its present forms, too: I am. You are. He is.

Past tense forms of “be” are tough for nonnative speakers to learn. Today I am. Yesterday I was. In the past I have been. Today you are. Yesterday you were. In the past you have been.

So for irregular verbs, the only way to get past tense forms right is to memorize them — or look them up. Which brings us back to lay and lie.

The past tense and past participle of “lay” are the same: laid. Today I lay the rug on the floor. Yesterday I laid the rug on the floor. In the past I have laid the rug on the floor.

The past tense of “lie” is downright cruel: It’s “lay.” The past participle is “lain.” Today I lie down. Yesterday I lay down. In the past I have lain down.

NPR’s and NBC’s posts should have both used the past tense of lie, lay: Yesterday, Ginsburg lay in state.

You can find the past forms in your dictionary. Look up “lie” and next to it you’ll see “lay, lain,” which is how dictionaries show past tense and past participle forms, in that order. Look up “lay” and next to it you’ll see just “laid,” which is how dictionaries tell you that there’s just one form for both the past tense and past participle.

So you don’t have to memorize the past tense forms of “lay” and “lie.” But if you write or edit for a living, you should definitely look them up.

June Casagrande is the author of “The Joy of Syntax: A Simple Guide to All the Grammar You Know You Should Know.” She can be reached at

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