Meigs believed that since Lee had committed treason in deciding to fight against the Union, denying Lee use of the mansion after the war was a rough form of justice. Meigs decided that a large number of burials should occur close to Arlington House to render it unlivable. Officers were to be buried next to the main flower garden south of the house, and the first burial occurred here on May 17. Meigs ordered that additional burials commence immediately on the grounds of Arlington House in mid-June. When Union officers bivouacked in the mansion complained and had the burials temporarily stopped, Meigs countermanded their orders and had another 44 dead officers buried along the southern and eastern sides of the main flower garden within a month. In September 1866, the remains of 2,111 Union and Confederate soldiers who died at the First Battle of Bull Run, Second Battle of Bull Run, and along the Rappahannock River were buried on the former site of "the Grove", southeast of the mansion, beneath the Civil War Unknowns Monument. Robert E. Lee made no attempt to visit or restore his title to Arlington before his death in 1870. Mary Lee died in 1873, having visited the house only one more time, a few months before her death. Too upset at its condition, she refused to enter and left after just a few moments. In April 1874, Robert E. Lee's eldest son, George Washington Custis Lee, filed suit against the United States government in a Virginia circuit court to regain his property. Custis Lee was a major general in the Civil War and was captured by Union forces at the Battle of Sailor's Creek on April 6, 1865 (see David Dunnels White). A jury found in favor of Custis Lee, leading to extensive appeals by both parties. In 1882, the Supreme Court of the United States ruled in favor of Lee in "United States v. Lee", 106 U. S. 196. The court, by a 5–4 majority, found that the estate had been "illegally confiscated" in 1864 and ordered it returned. But Lee was less interested in obtaining the estate than he was in a cash compensation for its value. After several months of difficult negotiations, Lee and the federal government settled on a sale price of $150,000 ($ in dollars). Congress enacted legislation funding the purchase on March 3, 1883; Lee signed over the title on March 31; and the title transfer was recorded on May 14, 1883. In 1920, the Virginia General Assembly changed the name of Alexandria County to Arlington County to end ongoing confusion between Alexandria County and the independent city of Alexandria.