Apple's policies around deceased users' hardware and accounts has recently (early 2015) changed, so it's possible this particular problem wouldn't happen again.

Apple's policies around deceased users' hardware and accounts has recently (early 2015) changed, so it's possible this particular problem wouldn't happen again. Dead users do appear to happen infrequently enough that not every CSR seems to know what to do when you call in about one, though. However, without court orders of some sort, you're probably completely out of luck. A death certificate used to be enough, but no longer. I found myself in that particular edge case (along with two Canadian families) earlier this year, as a relative had passed away in a state that did not mandate probate, and the family had elected to not go through the courts, and so had no legal documentation establishing an executor or estate. Apple ultimately said that they needed a court order to close the account or transfer the purchases to another one, otherwise the account and login would remain active forever, period.