LawProse Lesson #203: “Lie low” or “lay low”?

Lie low or lay low?      Both phrases could be correct—it depends on the tense you are using. Use lie low in the present tense; lay low in the past tense. Ex.: The celebrity is lying low for a few weeks to avoid news reporters. Ex.: Last month, that same celebrity lay low to avoid the paparazzi. Ex.: He has lain low for almost a year. The base verb used here, of course, is lie, conjugated lie–lay–lain, not the transitive lay as is often misused in phrases such as lie down and lie low. Two interesting examples of the latter were drawn to our attention by Michael J. Young of Florence, South Carolina. He noted that the Associated Press writer got it wrong in reporting on the arrest of the “wealthy, eccentric” Robert Durst after an HBO documentary based on his life and alleged connection with three murders. Durst had been arrested, the reporters wrote, in a New Orleans hotel “where he had been laying low.” Read lying low. On the same day, Reuters got it right in a piece on Russian president Vladimir Putin. The reporter said that Putin was scoffing at rumors that he had been in poor health and had to “lie low” for a while. Further reading: Garner’s Dictionary of Legal Usage 528, 544 (3d ed. 2011). Garner’s Modern American Usage 501–03, 510 (3d ed. 2009). The Redbook: A Manual on Legal Style § 12.3, at 290 (3d ed. 2013).