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This question already has an answer here:

I was laying in bed or lying in bed?

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marked as duplicate by waiwai933 Jan 3 '15 at 11:01

This question has been asked before and already has an answer. If those answers do not fully address your question, please ask a new question.

It would be "I was lying in bed." But for simple past you would use "I lay in bed." – Robusto Aug 28 '12 at 20:36
up vote 4 down vote accepted

According to Google NGrams, "lying in bed" is much more common.

"To lay" is a transitive verb. It can be reflexive - "I lay myself", "I am laying myself", "I was laying myself" - but it requires an object noun.

"To lie" by contrast is intransitive. It is an indicator of state, not action. Thus, your statement, which indicates your state in the past perfect, should use this verb and not "lay".

If "I was laying in bed", the connotation is that I was in the act of laying something in that bed, and the sentence is not proper unless that object is either stated explicitly or inferred by context; it can range from the innocent reflexive ("I was laying myself in bed") to the innocent transitive ("I was laying my infant daughter in bed") to the sexual ("I was laying my girlfriend in bed") to the absurd ("I was laying eggs in bed").

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To add to this, laying for lying is dialectal and locally valid (certainly round here in Sussex, England) but definitely non-standard. – Andrew Leach Aug 28 '12 at 21:04
+1 for the explanation, but, even though I am a fond of NGrams, I think they are a better guide to usage than grammar. – bib Aug 28 '12 at 21:59
There is much to be said for "correct by common usage". It's how languages evolve. Otherwise, we'd still be speaking Anglo-Saxon (if that). – KeithS Aug 28 '12 at 22:19

"I was lying in bed" is correct unless, of course, like a chicken you were laying an egg!

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You are most probably lying in bed.

Unless you are a hen and you are laying eggs in someone's bed, that is.

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