One would hope that Uzzah's punishment of death, carried out immediately by God, would not extend to a resurrection to further punishment, as opposed to a resurrection to eternal life, but then again ....
The is no definitive answer to this question, except to say:
- the ark should have been carried on poles by the designated priests; that is, it should not have been on a cart
- it should have been covered
- it should never be touched by anyone
All that one can say here is to presume that the severe penalty suggests that Uzziah must have been aware of all this and perhaps allowed the Ark to be transported in such an unseemly way. Note the comments of Ellicott:
(7) For his error.—The original is hero very obscure: 1 Chronicles 13:10 has “because he put his hand to the ark.” (Comp. 1Samuel 6:19.) Especial sacredness was by the law attached to the ark, and it was strictly commanded, that when it was to be moved it should be first covered by the priests, and then borne by the Levites by means of its staves; but until it was covered, the Levites might not look upon it, and might not touch it, upon pain of death (Numbers 4:5; Numbers 4:15; Numbers 4:19-20). Uzzah was probably a Levite, or, at any rate, had been so long in the house with the ark that he ought to have made himself familiar with the law in regard to it. What may seem, at first thought, an exceeding severe penalty for a well-meaning, though unlawful act, is seen on reflection to have been a very necessary manifestation of the Divine displeasure; for this act involved not only a violation of the letter of the law (of which David also was guilty), but a want of reverence for the majesty of God as symbolised by the ark, and showed a disposition to profane familiarity with sacred things. “Uzzah was a type of all who, with good intentions, humanly speaking, yet with unsanctified minds, interfere in the affairs of the kingdom of God, from the notion that they are in danger, and with the hope of saving them” (O. von Gerlach). Judgments of this kind were, however, temporal, and give in themselves no indication of the treatment of the offender beyond the grave.
By focusing on the holiness of the ark and the death of Uzzah, we may miss an important point: which is that David's heart was not right. He, more than Uzzah, was careless in his attitude but God protected him. In that sense, Uzzah died for David's mistake.
2 Samuel 6:8-10
8David was angry because the Lord’s wrath had broken out against Uzzah... 9 David became frightened of the Lord that day, and he said, “How can the ark of the Lord come to me?” 10 So David was unwilling to take the ark of the Lord with him into the City of David. David deposited it instead at the house of Obed-edom the Gittite.
David's concerns here do not put God first. He is angry that God's wrath has broken out. He is frightened and wonders how the ark can come to him. But the issue is resolved in the second attempt. In the interim he apparently consults with priestly authorities, as he should have done earlier.
2 Samuel 6:12-15, 17-19
12... David went to bring up the ark of God from the house of Obed-edom into the City of David with joy. 13 As soon as the bearers of the ark of the Lord had advanced six steps, he sacrificed an ox and a fatling. 14 Then David came dancing before the Lord with abandon, girt with a linen ephod. 15 David and all the house of Israel were bringing up the ark of the Lord with shouts of joy and sound of horn... 17 They brought in the ark of the Lord and set it in its place within the tent which David had pitched for it. Then David sacrificed burnt offerings and communion offerings before the Lord. 18 When David had finished sacrificing burnt offerings and communion offerings, he blessed the people in the name of the Lord of hosts, 19 and distributed among all the people, the entire multitude of Israel, to every man and every woman, one loaf of bread, one piece of meat, and one raisin cake. Then all the people returned to their homes.
Not only did priests now carry the ark on poles to prevent tipping, but every six steps the bearers of the ark stopped and David sacrificed an ox and a fatling (probably meaning he caused them to be sacrificed rather than doing this himself). In other words, David had carefully consulted with priestly authorities. The ark, after all, does not belong to him but to God. He also acted as a true leader of the people, demonstrating passionate, joyful worship of the Lord. David clearly repented for his earlier careless attitude. God now blessed the event, and David shared the offerings victoriously with the people.
Conclusion: In the first attempt, David had not prepared, either in his heart or in terms of logistics in consultation with priestly authorities. He was spiritually and physically careless, and Uzzah bore the tragic consequence of David's mistake. In the second attempt, David demonstrated his most important redeeming characteristic: his willingness to repent and change his attitude and behavior to re-unite his heart with God.