Her cousin Les Berman says Bay died Thursday at a Los Angeles area hospital after being diagnosed with pneumonia.
After working as a radio actress before World War II, Bay married and became a housewife. She returned to acting in the 1970s and her career took off. Bay played Fonzie's Grandma Nussbaum on "Happy Days" and kindly older ladies in shows like "The Jeffersons," "The Dukes of Hazzard" and "Who's the Boss?"
The Canadian-born actress also was cast by director David Lynch in several films, including "Blue Velvet" and "Wild at Heart."
Fans of "Seinfeld" know her as the tough lady who fought with the show's star over the last loaf of bread.
She has no immediate survivors.
