The verb lay is a transitive verb. Transitive verbs require two arguments: a subject and a direct object. Which leaves me wondering, what did the dead lay?
And more importantly, how?
In addition to requiring a particular number of arguments, different verb types also maintain different semantic restrictions.
In linguistics, these restrictions are monitored by what are known as theta roles (which equate to the number of arguments required by the verb). Every verb is encoded with a minimum of one theta role and a maximum of three. Theta roles are filled by words or phrases that carry certain thematic relations. Thematic relations being the semantic relation between an argument and its predicate (verb).
The verb lay mandatorily has two theta roles to fill, which are most commonly filled by words or phrases with the thematic relations agent and theme. An agent is an initiator or doer of an action. A theme is an entity that undergoes an action, is experienced or is perceived.
By the thematic role definition, the verb lay requires an animate subject because an inanimate subject cannot initiate an action. So I pose the question again, how can the dead lay? Dead are inanimate by definition; they are not capable of initiating an action.
If, by any chance, the title's use of lay is as the past tense of the verb lie it still doesn't jibe semantically...unless, of course, you believe in the ability of the dead to rise.
Click here for more on the distinction between "lay vs. lie".