Levels of Distractibility: Who cares? = *. Some people will be distracted from your meaning: = **. Many people will be distracted from your meaning: = ***.
Comment: People who should know better--the news media, print and TV--completely blow the distinction between "lie" and "lay." I'd like a nickel for every time I have heard the reporters on Philadelphia's Channel 6 Action News say, "...laying in the streets." I rarely have heard these terms used in recent years on those newscasts. I think the station's management has proscribed their use, knowing that almost 100% of the time they will be used incorrectly. I've even seen its misuse in that most well-edited-newspaper-in-the-world the Wall Street Journal.
Advice: I have some advice: If you are concerned about using these terms correctly, don't use them. Write or speak around them. Find some other words to express the same idea. If you try to use "lie" and "lay," you will almost certainly be wrong.
"Lie," "lay," "lain," "lying" and don't forget, "...had lain" mean to rest or recline. "He lay on the sidewalk." "He was lying on the sidewalk."
"Lay," "laid," "laid," "laying" and don't forget, "...had laid" mean to put or place. "He lay the hammer on the table." "He laid the hammer on the table." "Lay, laid, laid" take a direct object; you put something somewhere. With "lie," "lay" and "lain," there is no direct object.
I predict that in the distant future, "lay," "laid" and "laid" will obliterate "lie," "lay" and "lain." The latter will become extinct.
Rating of Distractibility: ***. The mistake is as obvious and egregious in speaking as in writing. In speaking, it is more difficult to sort through the choices in an instant. In writing, you really should not make the mistake. You have time to get it right. However, if you do make the mistake, you can be comforted that you have almost 100% of other Americans who will make the same mistake. RayS.