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JONES, WALKER, WAECHTER, POITEVENT,

CARRÈRE & DENÈGRE, L.L.P.

201 St. Charles Avenue

Suite 5100

New Orleans, LA 70170

August 25, 2005

VIA EDGAR AND FEDERAL EXPRESS

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Ms. Kathryn T. Jacobson

                 RE:

    Stewart Enterprises, Inc.

Form 10-K for the Fiscal Year Ended October 31, 2004

Filed January 11, 2005

    Form 10-Q

For the Quarterly Period Ended January 31, 2005

    Form 10-Q

For the Quarterly Period Ended April 30, 2005

Your File No. 1-15449

Ladies and Gentlemen:

     On behalf of Stewart Enterprises, Inc. (“Stewart” or the “Company”), we are submitting this
letter to supplement the Company’s letter dated August 11, 2005 for the purpose of responding to
the questions raised by the Commission’s staff (the “Staff”) in the August 16, 2005 conference call
among the Company, its independent accountants and certain members of the Staff. We have numbered
and addressed the Staff’s questions in italics, each of which is followed by Stewart’s response.

Issue 1. Whether the Company should discuss adjusted gross profit or another measure of segment
profitability, in addition to or in lieu of discussing GAAP gross profit, in its MD&A and/or its
segment disclosures.

Response 1. In its response dated August 11, 2005, the Company offered quantitative documentation
supporting its position that its US Cemetery and all Funeral operating segments possess economic
characteristics that are similar and that those similarities satisfy the criteria in paragraph 17
of SFAS 131 that permit aggregation of these operating segments for reporting purposes.

Securities and Exchange Commission

August 25, 2005

Page 2

All of the profitability metrics discussed in the August 11 response, except adjusted gross margin,
are contained in the CODM financial package and are used by the CODM to assess performance and
allocate resources. Adjusted gross margin is not a metric the CODM uses to allocate resources and
assess performance.

The one metric that arguably indicated a lack of comparability among the divisions was the
Company’s G&A expense category. Upon further reflection and consideration of the divisional
activities that are supported by those G&A expenses, management recognized that the preneed sales
effort represented a significant activity that should be considered in assessing economic
similarity. As the Staff knows, revenue from preneed sales is deferred and recognized only when
the service is performed or the merchandise is delivered at an unspecified time in the future.

Management therefore concluded that for purposes of measuring economic similarity under paragraph
17, it would make sense to adjust revenues to include preneed sales, which absorb a portion of the
G&A expense, and to include the related direct costs associated with preneed sales and to then
compare the resulting adjusted gross margin across divisions.

Management’s purpose in preparing this non-GAAP metric was to demonstrate why it believed its
divisions were economically similar, and to effectively compare divisional performance for purposes
of determining if it would be appropriate to aggregate operating segments in accordance with SFAS
131. This measure has not historically been used by the CODM in managing the Company’s business
and was not intended to serve as a substitute for a measure such as gross profit (as included in
the CODM package) or the other profitability metrics the CODM uses in analyzing the business of the
Company for any other purpose.

The Company believes that gross profit is the GAAP measure that is most consistent with the
aggregation of the various profitability metrics that are regularly reviewed by the CODM and is an
appropriate measure for discussion in the Company’s MD&A and other public disclosures.
Accordingly, the Company believes its disclosures in that respect have provided investors with all
information necessary to make informed decisions. However, the Company has also given consideration
in its MD&A to the impact of its preneed sales efforts and the significance of those efforts in
managing the business and allocating resources. In view of the Staff’s comments and the Company’s
reconsideration of its operating segments, the Company will add information to its segment footnote
disclosures that quantifies its preneed sales.

The Company will not aggregate its operating segments under SFAS 131 but rather present all of its
operating segments as reportable segments as allowed under paragraph 17 of SFAS 131, with the
exception of the Puerto Rico funeral and cemetery operating segments which do not meet the
quantitative tests for disclosure as a reportable segment. These operating segments will be
reported in the All Other category. Please see Appendix I for the proposed disclosure template.

Securities and Exchange Commission

August 25, 2005

Page 3

Issue 2. Whether the Company’s Florida funeral operating segment is economically similar to the
other operating segments and, in particular, whether year-to-date performance is more
representative of what the Company expects going forward or whether Budget 2005 is more
representative of the Company’s expectations.

Response 2. As discussed in Response 1, the Company proposes not to aggregate its operating
segments under SFAS 131 but rather present all of its operating segments as reportable segments as
allowed under paragraph 17 of SFAS 131. As a result, this issue is no longer relevant.

Issue 3. Whether the Company’s trust activities reported separately on pg 10 of the CODM package
should be considered a separate operating segment. If not, whether those earnings should be
included as a reconciling item to arrive at consolidated funeral and cemetery revenue.

Response 3. Page 10 of the CODM reporting package includes (i) the trust earnings recognized for
GAAP purposes, which are further described below, (ii) fee income related to the Company’s
wholly-owned subsidiary, Investor’s Trust, Inc., “ITI” and (iii) and miscellaneous closing accrual
and adjustments required for purposes of preparing the consolidated financial statements.

Trust assets, and the earnings on those assets, are associated exclusively with preneed sales. The
Company sells preneed funeral and cemetery contracts through various programs. Because the
services and merchandise will not be provided until an unknown future date, most states require
that all or a portion of the customer payments under these contracts be set aside for the benefit
of the customers pursuant to state laws that often require the funds to be placed into trust
accounts. These trust assets are described in significant detail in Notes 4, 5, 6, and 7 in the
Company’s Form 10-K for the year ended October 31, 2004. The disclosure also includes the cost
and market value of the trust assets in each period.

As disclosed on page 11 of the Company’s Form 10-K for the year ended October 31, 2004, ITI serves
as investment advisor to the Company’s trust funds. ITI provides investment advisory services to
the Trusts for a fee. Under trust laws, the Company is allowed to charge a fee for managing the
investment of the trust assets. The Company has elected to perform these services in-house and the
fees are recognized income as earned. ITI’s revenues are included on page 10 of the CODM package
on line items 9 and 23 as ITI fees.

The trust earnings recognition data on page 10 of the CODM package (lines 8 and 25) reflects the
realized earnings related to preneed contracts delivered and represents earnings realized over the
life of the contracts delivered during the relevant periods. Earnings recognition as reported on
page 10 is unrelated to investment management activities in the current period. Also, additional
information related to the Company’s

Securities and Exchange Commission

August 25, 2005

Page 4

trust funds and current performance of the trust funds are provided to and reviewed separately by
the CODM. Current investment results of the funeral and cemetery merchandise and service trust
funds are deferred and are not reflected in the income statement but are disclosed in Notes 4, 5,
and 7 of the Company’s Form 10-K for the year ended October 31, 2004 along with the cost and market
value of the trust assets. The Company’s activities related to management of its trust assets, the
investment income related to preneed contracts delivered and the trust assets are referred to as
Corporate Trust Management for the benefit of the divisions.

Perpetual care trust earnings are reported on the geographic division pages in the CODM package as
these revenues are recognized currently and are used to maintain the cemeteries. Perpetual care
trust earnings (line 26 in the CODM package) are included in the analysis the Company performed to
assess the economic similarity of the geographic divisions as this is how management reviews the
data. As such, perpetual care trust earnings are included in the Cemetery segment in the Central,
Eastern, Western and Florida operating segments in Appendix I and are disclosed in Note 7 of the
Company’s Form 10-K for the year ended October 31, 2004. The cost and market values of the
perpetual care trust assets are presented in Note 6 of the Company’s Form 10-K for the year ended
October 31, 2004.

The Company has historically included the results of both Corporate Trust Management and ITI in its
funeral and cemetery segments and has separately disclosed the results of the trust activities in
the Notes to its consolidated financial statements. The Company has reexamined the criteria in
paragraphs 10 and 11 of SFAS 131, determined that the Trust operations are managed together and
reviewed by the CODM regularly and proposes to treat its Trust operations as a separate operating
segment. Accordingly, the Company will separately present the Corporate Trust Management function,
which would include the trust assets and the trust earnings recognition data on page 10 of the CODM
package (lines 8 and 25) as well as the fee income attributable to the ITI operations (lines 9 and
23 of the CODM package). Please see Appendix I for the Company’s proposed disclosure template for
this information.

Issue 4. The Staff asked for additional quantitative analysis considered by the Company in
determining its reporting units for purposes of applying SFAS 142.

Response 4. Paragraph 30 of SFAS 142 requires that two or more components of an operating segment
be aggregated if the components have similar economic characteristics as defined in paragraph 17 of
SFAS 131 and EITF Topic D-101 (“D-101”). As noted previously, the Company’s components as defined
in paragraph 30 of SFAS 142 are its regions. As specifically outlined in D-101, this assessment
should be more qualitative than quantitative. The Company believes that there are no inherent
differences in the service offerings within regional operations and that the manner in which the
Company supports its operations through the Company’s Shared Services Center (“SSC”) and shares
resources within divisions provides a strong basis for aggregating the regions. Under the guidance
of D-101, no single factor or characteristic is considered

Securities and Exchange Commission

August 25, 2005

Page 5

determinative. Accordingly, the Company has evaluated all qualitative and quantitative
characteristics as outlined below. The Company believes the qualitative factors support
aggregating certain of its regions. However, when considering quantitative factors as well, the
Company believes that certain regions within its Western Division, as further discussed herein,
should be considered separate reporting units. For the remainder of the Company’s regions, the
Company has concluded that the quantitative and qualitative analysis requires the regions to be
aggregated for purposes of determining reporting units under SFAS 142.

The Company’s analysis is as follows:

Qualitative Considerations

A summary of the qualitative factors considered is as follows:

    •

    Regarding paragraph 17(a) of SFAS 131, the nature of the Company’s products and
services is similar in each of the funeral homes and cemeteries in each region.

    •

    Regarding the criteria of paragraphs 17(b) and (d) of SFAS 131, the Company’s
products and services, such as caskets, personalization of services and limousine
services, are consistent in all funeral homes and cemeteries, as are the means of
delivering those products and services.

    •

    Regarding the criteria of paragraph 17(c) of SFAS 131, the type or class of
customer is similar across all locations and tends to be middle- to upper-income
consumers. The Company appeals to this consumer group because the Company tends to
own large funeral homes in large metropolitan areas that are among the most highly
regarded in their market area in terms of such factors as tradition, heritage,
reputation, name recognition, volume of business and aesthetics.

    •

    Regarding the criteria of paragraph 17(e) of SFAS 131, the Company’s funeral
business and cemetery business are regulated by different jurisdictions, but in a
consistent and similar manner.

    •

    The Company’s operations are managed centrally and on a geographic basis depending
on key functions. As the Company has previously discussed in its responses to the
Staff, the Company believes it operates a quasi-matrix organization in which key
strategic directives, administrative decisions and complementary service and support
activities are managed centrally, divisionally and on a functional basis through the
Company’s SSC, while the delivery of its death care services to the end customers, in
both its cemetery and funeral operations, are managed geographically.

Securities and Exchange Commission

August 25, 2005

Page 6

    •

    Goodwill is recovered from the synergies and economies of scale of the combined
network. Recovery of cash flows from operations is driven by the Company’s strategy
to integrate the roof-top locations using centralized management policies and
procedures and anticipates the sharing of resources through the Company’s SSC and
regional and divisional operations. In certain regions, the Company shares facilities
(such as a central prep room), equipment (such as a limousine fleet or equipment used
in the cemetery), personnel and sales force. In addition, the regions within
divisions often share inventory, removal functions, cemetery grounds crews and
advertising dollars through combined campaigns. There is also significant sharing of
resources throughout the consolidated group as previously discussed

Quantitative Factors

The Division presidents review a variety of metrics when assessing the performance of the regions.
For purposes of analyzing whether or not the divisions are considered economically similar, the
Company has analyzed gross margins and has also considered the comparability of the adjusted gross
margin metric (defined in the Company’s previous response), when preneed sales efforts in the
division are significant, and also has evaluated direct gross margins, which exclude G&A.

In Exhibit I, the Company is providing to the Staff separately pursuant to a Freedom of Information
Act confidential treatment request illustrating the actual 2002 through April 30, 2005 and budgeted
2005 funeral and cemetery gross margin percentages for each of its 27 components (14 funeral
components and 13 cemetery components). There are no regions in the Puerto Rico operating segment.
Thus, the operating segments are the reporting units. Puerto Rico is not presented in a table as
there is nothing to aggregate. Each of the operating segments, except Puerto Rico, is shown in a
separate table with all of the regions that make up that operating segment. Thus there are 8
tables. Direct gross margins and adjusted gross margins were also calculated