Once a person dies, libel laws no longer apply. Anyone can pay to publish a nasty obit about them if the newspaper wants to take the money for the obit. Why a person wants to pay to publicly denounce the deceased is about them. This is how this person dealt with the death of a difficult person. I do know someone who called his/her father “the devil”, but didn’t pay to put that in an obit. The obit may help subsequent generations understand the generation above them in the family history.
Thats not accurate, exactly
There is a tort called “tarnishing the memory of the dead.” The estate can bring the claim.