Appellate Court deems funeral luncheons to be reimbursable funeral expenses under Ohio law

In re Estate of Campbell, 2013-Ohio-1356, 989 N.E.2d 1090 (6th Dist. 2013). The 6th District Court of Appeals held that a funeral luncheon qualifies as a reimbursable funeral expense under O.R.C. § 2117.25(A)(2). Ohio statutory law provides that a person, other than the surviving spouse who pays for funeral expenses, is entitled to reimbursement of reasonable expenses from the estate. With no case law discussing whether funeral lunches were ordinary funeral or burial expenses under the statute, the Appellate Court found funeral expenses to have a broad definition that encompasses the entire funeral process. Interpreting the statute, the Appellate Court found its language to support the assertion that funeral expenses encompass more than simply the funeral ceremony itself. In support of its reasoning that the funeral luncheon is an integral part of the funeral and a clear funeral expense, the appellate court stated that people who attend the funeral and burial ceremonies ordinarily attend funeral luncheons. Additionally, the Appellate Court found that the funeral luncheon is a custom that has been widely observed for a millennia in connection with the funeral itself because the practice dates back to ancient Roman times.