As TweedleZildian implied, words and rules about them go very wobbly in this area.

I think that's because this rule, if it indeed it ever had any value and isn't just a collection of coincidences, is no longer, as the linguists like to say, productive. The lie/lay thang is very much ignored. I was having a discussion on lie/lay on Dave Wilton's wordorigins board some time ago and a couple of the defenders of the lie/lay distinction quoted Bob Dylan and Eric Clapton saying they couldn't imagine singing "Lie, lady, lie" or "Lie down, Sally".