Note: this exception is addressed in the 4th edition of The Ultimate Guide to SAT® Grammar and the 3rd edition of The Complete Guide to ACT® English, but it is not covered in earlier versions.

 

Both SAT Writing and ACT English focus test two specific aspects of the who vs. whom rule.

 

1) Who, not whom, should be placed before a verb.

 

Incorrect: Alexander Fleming was the scientist whom discovered penicillin.

Correct: Alexander Fleming was the scientist who discovered penicillin.

 

2) Whom, not who, should follow a preposition (e.g., of, from, for, with, by, in, to, about).

 

Incorrect: Alexander Fleming was the scientist by who penicillin was discovered.

Correct: Alexander Fleming was the scientist by whom penicillin was discovered.

 

Now, there is one instance in which both of these scenarios can be combined. It involves the construction pronoun + of whom, e.g., some of whom, most of whom, many of whom, none of whom, etc.

 

When one of these formations appears, it is acceptable for the word whom to come before a verb. In such cases, rule #2 takes precedence: the fact that whom must follow the preposition of outweighs the presence of the verb afterward.

 

Incorrect: Alexander Fleming was the first scientist to isolate penicillin; however, the drug was purified for distribution by a team of researchers that included Ernst Chain and Howard Florey, neither of who received the kind of popular acclaim given to Fleming.

Correct: Alexander Fleming was the first scientist to isolate penicillin; however, the drug was purified for distribution by a team of researchers that included Ernst Chain and Howard Florey, neither of whom received the kind of popular acclaim given to Fleming.

 

In the sentence above, it is acceptable for the verb received to be placed where it is because whom is part of the phrase neither of whom.