Here’s a curious incident at the NYT, courtesy of author and economist Paul Krugman. On Twitter yesterday, Krugman mentioned an upcoming article and attempted to forestall criticism of its headline’s grammar:
The implication was that the headline would include, per Krugman’s preference, the word who where traditionalists would insist on whom. The rule mandating whom as object pronoun is relatively recent and often ignorable, but style guides are necessarily conservative.
NYT style upholds the rule, as you’d expect, but its writers (or copy editors) repeatedly get confused, often hypercorrecting who to whom in a misguided effort to be formally grammatical. In short, it’s a mess, and much of the confusion results from people’s belief (or nervous suspicion) that whom must always be used where it’s grammatically possible.