Ohio Court Says Funeral Luncheon is a Reimbursable Expense

Lunch for mourners after a funeral is typical in many traditions. Recently, an Ohio court decided if lunch following a funeral was a reimbursable expense. In 2011, Kathy Campbell died. Her willappointed Joan Torzewski as the executrix of the estate. Campbell’s willindicated that all funeral expenses should be paid out of her estate. Joan’s siblingswere reimbursed $1,800 dollars for a funeral luncheon they had paid out ofpocket for. Joan claimed that the lunch was a critical part of the funeral ceremonybecause of Polish tradition. The reimbursement was challenged. 

In re Estate of Kathy M. Campbell, a case of first impression, the Ohio intermediate appellate court held that the cost for a funeral luncheon is a reimbursable funeral expense under the Ohio law. The court reasoned that under the Ohio Revised Code 2117.25  the lunch was not excluded from being considered a funeral expense. Additionally, the lunch was a reasonably incurred expense because people ordinarily include a luncheon following a burial.

In re Estate of Kathy M. Campbell, No. WD-12-028, 2013 WL 1385635 (Ohio Ct. App. Apr. 5, 2013).

Special thanks to William LaPiana (Professor of Law, New York Law School) for bringing this case to my attention.