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Bar Association of San Francisco Member Benefits: Publications

Legal Writing Tip: Who vs. Whom


By Leslie A. Gordon, BASF Bulletin Contributor


Determining when to use the pronouns who and whom can be confusing, particularly because whom isn’t used much in contemporary colloquial speech. Yet it’s important to know the correct application in writing. Use who for the subject of a clause, the person doing something. Alternatively, use whom for the object of a clause, the person having something done to them, the receiver of action. (Note: for inanimate objects and animals without a name, use that and which instead.)

For example:

Who hired you?

Who knocked into Sally?

The man who rented the car damaged it.

Who sees you?

Those sentences are asking about the subject, the person taking action, so who is appropriate. Conversely, the following sentences focus on the sentence’s object so whom is correct.

Whom did you hire?

Whom do you knock into?

The man to whom the car was rented damaged it.

Whom do you see?

Importantly, always use whom after prepositions (to, with, by, on, in, etc.) and remember that rules about ending sentences with prepositions have been widely relaxed.

With whom did you see Stan?

One memory trick is to ask whether the answer to the question would be he or him. If it’s he (or they), use who; if it’s him (or them), use whom.

Who/whom wrote the opinion? He did so who is correct.

Who/whom should I vote for? I vote for him so whom is correct. (Note that the preposition is at the end but for still governs whom.)

When you have two clauses, break it apart:

We know who/whom played that joke. He played that joke so who is correct.

We know on who/whom that joke was played. It was played on him so whom is correct.

Rules regarding whomever/whoever are surprisingly complicated – we’ll cover that in a future column.


A former lawyer, Leslie A. Gordon is a freelance journalist living in San Francisco.

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