Exhibit 18






December 15, 1999

Board of Directors
Stewart Enterprises, Inc.
110 Veterans Memorial Blvd.
Metairie, LA  70005

Dear Directors:

We are providing this letter to you for inclusion  as  an exhibit to your Form
10-K filing pursuant to Item 601 of Regulation S-K.

We have audited the consolidated financial statements in  the Company's Annual
Report on Form 10-K for the year ended October 31, 1999 and  issued our report
thereon dated December 15, 1999.  Note 3 to the financial statements describes
a  change  in  accounting  principle  from  recognizing, prior to delivery  of
service,  a  portion of earnings realized by irrevocable  prearranged  funeral
trust funds and  escrow accounts to deferring 100 percent of earnings realized
by irrevocable prearranged  funeral  trust funds and escrow accounts until the
time of delivery of service.  It should  be  understood that the preferability
of  one  acceptable  method of accounting over another  for  funeral  services
investment trust fund  earnings  has  not  been addressed in any authoritative
accounting literature, and in expressing our  concurrence below we have relied
on  management's determination that this change  in  accounting  principle  is
preferable.    Based  on  our  reading  of  management's  stated  reasons  and
justification for  this  change  in accounting principle in the Form 10-K, and
our  discussions with management as  to  their  judgment  about  the  relevant
business  planning  factors  relating to the change, we concur with management
that such change represents, in the Company's circumstances, the adoption of a
preferable accounting principle in conformity with Accounting Principles Board
Opinion No. 20.

Very truly yours,



PricewaterhouseCoopers LLP
New Orleans, Louisiana