FWIW Garner classifies this error as "stage 1" (rejected) in a recent edition, so we're still safe for a while, at least in professional writing. However, I do

FWIW Garner classifies this error as "stage 1" (rejected) in a recent edition, so we're still safe for a while, at least in professional writing. However, I do see this mistake more often than I see either word used correctly in non-professional Web writing, to include much work that is paid, but neither written nor edited at anything like a professional level. Garner attributes the error—among pros, anyway—to closeness to "leery". I'd guess it's more often just bad phonemic awareness when committed by the general public, though.