Why do so many people have trouble with "lay" and "lie"? It's not that difficult. Law enforcement people seem have particularly difficulties. On almost every true crime show I watch, and I watch a
lot, the detective or police officer will always say, "the body was laying there." Of course a lot of these  cops and detectives also say, "He should have went" or "If I would have known." I guess we can't expect them to capture criminals and the nuances of the English language.