What if the deceased is not a Christian? I have known preachers to state emphatically, “Johnny is in hell.” This is done in the name of being “truthful.” Others, will want to appease the fears of those in attendance when there is no possible ground for claiming the deceased knew the Lord as Savior.
Broadus, which is usual wisdom, gives the following instruction:
When the departed was not a Christian, he may sometimes lawfully speak a few soothing words as to anything which specially endeared the deceased to his friends. But this must be done, if done at all, without exaggeration, and it is a solemn duty to avoid saying one word which suggests that these good points of character afford any ground of hope for eternity. Some preachers will on such occasions give the lie to all their ordinary preaching, by leaving room to suppose that without being born again a very excellent person may perhaps see the kingdom of God. “He did not make any profession of religion, but he was this or that, and we leave him to the mercy of God.” Or, “he had never professed to be a Christian, but he was perfectly willing to die”—as if that proved anything. Nay, if the deceased did not give evidence of being regenerate, a believer in Christ, let us say nothing about his eternal future, nothing whatever. Any such suggestions encourage the ignorant or unthinking in false hopes, and to right-minded mourners are but a mockery of their woe. Pains should be taken not to make much of death-bed conversions, which are proverbially uncertain, and the hope of which, as a last resort, is so often taken by the living as an encouragement to delay. In general, the preacher ought to exercise reserve in what he says of the departed; and in the case of wicked people, it is frequently in the best taste, and shows the most real kindness, to say nothing. Young preachers sometimes allow themselves, in their first sermons of this sort, to indulge in copious eulogies with no great foundation, and then afterwards seem compelled to do likewise in cases where they feel it to be a great trial, and know that they are liable to do serious harm to the cause of truth. It will save much embarrassment to begin right.
John Albert Broadus, A Treatise on the Preparation and Delivery of Sermons, ed. Edwin Charles Dargan, New (23d) ed. (New York: Hodder & Stoughton, 1898), 102–103.