As I am talking to you right now, my mother is lying down in the hospital.

Source: https://punchng.com/policemen-killed-my-husband-left-me-helpless-pregnant-anambra-woman/

Back in the day, we celebrated Dodger pitching ace, Clem Labine; now we find Skippy Supine in the front office, lying down for the worst in our culture to roll right over him.

Source: https://spectator.org/dodgers-indeed/

But some have even turned their attention to the driver who, they believe, shouldn't have accepted the defeat lying down.

Source: https://www.dailymail.co.uk/news/article-12393521/I-accidentally-paid-someones-gas-no-one-decide-fault.html?ns_mchannel=rss&ns_campaign=1490&ito=1490

Clearly not used to being behind, Easterhouse started to lose some composure, although a team of this calibre were not going to take this lying down and again they levelled the score five minutes later.

Source: https://www.obantimes.co.uk/2023/03/27/lochnell-hold-easterhouse-in-impressive-draw/

Colt posted a photo of Colt lying down in a hospital bed on January 2, 2023.

Source: https://screenrant.com/90-day-fiance-colt-johnson-major-surgery-news/

His wife, Fiona, has a heightened sense of touch due to being profoundly visually impaired, and felt a lump in Darren's chest while he was lying down.

Source: https://www.expressandstar.com/news/health/2023/10/23/walsall-father-who-was-diagnosed-with-breast-cancer-urging-men-to-be-aware-of-symptoms/

In a different photo, she was also caught on cameras lying down with her head on her husband's thigh as he caressed her belly.

Source: https://www.aceshowbiz.com/news/view/00206137.html

I've also found that deep-throating is a lot easier on me if the person is sitting upright versus lying down.

Source: https://www.buzzfeed.com/spenceralthouse/best-sex-tips-for-everyone

I was lying down, drinking me a beer."

Source: https://abc13.com/texas-city-woman-shot-while-sleeping-shooting-at-house-heron-lane-shots-fired-home/13945517/

I wasn’t just going to take that lying down.

Source: https://metro.co.uk/2023/01/21/the-traitors-kieran-talks-parting-gifts-fan-selfies-and-celeb-dm-slides-18129299/

She's lying down unconscious, possibly even dead, but definitely unconscious.

Source: https://www.dailymail.co.uk/news/article-12652027/joran-van-der-sloot-confession-Natalee-Holloway-aruba-investigation-DOJ.html?ns_mchannel=rss&ns_campaign=1490&ito=1490

The “Hail Caesar!” actor screamed while lying down on the floor.

Source: https://centralrecorder.com/george-clooney-lived-with-unbearable-pain-years-before-meeting-amal-now-62-he-cooks-for-her-does-the-laundry/

The son of Amy and Matt Roloff posed with his three children, Jackson, Lilah Ray, and Josiah Roloff, while lying down on the couch at home.

Source: https://screenrant.com/little-people-big-world-zach-roloff-surgery-update/

This practice can be done lying down or sitting upright.

Source: https://www.popsugar.com/fitness/what-is-breathwork-49326408

“We sit but can’t sleep lying down here," he said.

Source: https://rapidcityjournal.com/news/world/rescuers-find-more-alive-in-turkey-more-aid-reaches-syria/article_4fcac8d4-01e7-5a35-8f21-a733546ec1f4.html