Just say who
Another one turns up, as it always does, on a page proof, after passing through the hands of a writer, an assigning editor and a couple of copy editors:
The FTC asked for the orders shutting the businesses and freezing assets without notifying the defendant, whom they believed would go into hiding.
The clause folded into that sentence is who would go into hiding.
Here’s the thing. Whom has an increasingly insecure perch in the language, and who is not only supplanting it in spoken English, but also increasingly in written English. So if you are a professional journalist — reporter, assigning editor, copy editor or whatever —and your grasp on the distinction between subject and object is a tenuous, the safe bet is to use who in all cases, since whom is the thing you’re apt to get wrong. At the worst, you’ll be thought casual rather than ignorant.
Purists will fret, but they enjoy that. It gives their lives meaning.