United States v. Lee (1882)
With local cemeteries in Alexandria County and Alexandria filling rapidly with war dead, Quartermaster General of the United States Army Montgomery C. Meigs proposed using of the Arlington estate as a cemetery. The first burial there was made on May 13, 1864. United States Secretary of War Edwin M. Stanton approved the establishment of a military cemetery on June 15, 1864, creating Arlington National Cemetery. By the end of the war in April 1865, more than 16,000 people had been buried at Arlington. In September 1866, a memorial and a burial vault (containing the remains of 2,111 U.S. and Confederate soldiers who died at the First Battle of Bull Run, Second Battle of Bull Run, and along the Rappahannock River) were buried in Lee's former wildflower garden on the mansion's east side beneath the Civil War Unknowns Monument, a memorial to honor unknown soldiers who had died during the American Civil War.
List of memorials and monuments at Arlington National Cemetery
In 2012, legislation began moving through Congress to approve a "Place of Remembrance" at Arlington National Cemetery. The memorial will be an ossuary designed to contain fragments of remains which are unidentifiable through DNA analysis. The legislation required that these remains be cremated before placement in the memorial. Cemetery officials said that Arlington National Cemetery has no means of receiving and burying these remains, and placing them in the Tomb of the Unknowns would be inappropriate. The legislation leaves the design and placement of the memorial up to cemetery officials. On September 18, 2012, the House of Representatives approved the memorial, sending the legislation to the Senate. This legislation was not acted on by the Senate, and died at the end of the 112th United States Congress.