I won’t subject readers to another long, rambling post on whom. But I want to note the tendency, strongest among those who are anxious to use whom “correctly”, to use it even when who would be generally considered the grammatically appropriate choice: as subject pronoun.
Ben Zimmer at Language Log recently criticised a book review at the New Yorker in which Nathan Heller wrote: “The glorious thing about the ‘who’ and ‘whom’ distinction is that it’s simple.” This is an easy assumption to make if your grasp of who/whom grammar owes to the oversimplified instructions of the many prescriptive guides that neglect to examine register* or the trickier possible cases.
As Zimmer points out, Heller also wrote (unless his New Yorker editor is responsible): “But what about Sir Isaac Newton, whom some contend was autistic?” This hypercorrection shows why who/whom usage is not simple. The recursive structure in the Isaac Newton line is a frequent source of confusion, not least among journalists. It recurs on the NY Times‘s grammar and usage blog After Deadline:
There’s no reason to think this uncertainty will abate any time soon. As John E. McIntyre observes from the Baltimore Sun copy desk:
Colleagues, literate, educated, adult native speakers making a living with words, regularly come up to me to ask, “Should this be who or whom in this sentence?” . . . And that’s in ordinary, journalistic sentences, not rococo Nabokovian constructions.
Even when they do try to work it out, they commonly get it wrong. One of the most common errors it falls to my lot to fix is whom as the subject of a clause that is the object of a verb or preposition.
This is what happened in Heller’s line (But what about Sir Isaac Newton, whom some contend was autistic?). It looks like a straightforward grammatical structure, but this seeming simplicity is deceptive and leads many writers astray. It may help to think of “some contend” for a moment as peripheral or parenthetical, and focus only on the embedded relative clause. Ben Zimmer again:
the “who(m)” fills the slot in the clause “Some contend (that) ___ was autistic.” It’s the subject of the embedded relative clause “___ was autistic,” but it’s tempting to use “whom” in sentences like this, if you’re the type of person looking to use “whom” in the first place.
Which brings us to what I’ve dubbed Whom’s Law: The more strict or anxious someone is about using ‘whom’ correctly even in informal English, the more likely they are to use it hypercorrectly.
By hypercorrectly I mean subject whom, as in the examples above, or in *Whom shall I say is calling?, where the embedded relative clause is Who is calling?. Whom here may be an effort to sound as formally correct as possible, or to err on the side of caution. But the proximity of shall I say wields undue influence, and error duly results.
For something that began as a philosophical pun, the parallels with Hume’s Law (also known as the is–ought problem) are pleasing. To use RationalWiki’s phrasing, Hume’s Law says “you can’t derive an ‘ought’ from an ‘is’. The law is also a rebuttal of the naturalistic fallacy, or inferring how the world ought to be from the way it is or was in the past.” And whom, if not exactly moribund, is in long, steady decline.
A caveat: MWDEU notes that Otto Jespersen defended subject whom, and it shows up in the work of Shakespeare, Dickens, Boswell, and other accomplished writers. But the widely recommended convention in contemporary prose is to use whom only as an object pronoun – and then only according to audience, taste, syntactic context, and degree of formality desired.
* To use my earlier description: Register in linguistics and stylistics refers to the type of language used in a particular social scenario or field of discourse, often with regard to the degree of formality.