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
The rules were relaxed somewhat in 2012. On August 6, 2012, Congress enacted the "Honoring America's Veterans and Caring for Camp Lejeune Families Act of 2012" (P.L. 112-154; 126 Stat. 1165). Title VI, Section 604 of this legislation permits the Secretary of the Army to establish regulations for the erection at Arlington National Cemetery of memorials or monuments to an individual or military event if 25 years have passed. Such monuments may be placed only in areas designated by the Secretary of the Army, and must be paid for entirely by private donations. All alternative locations to Arlington National Cemetery must be ruled out, and the United States Commission of Fine Arts must be consulted on the memorial's appropriateness. The 25-year requirement may be waived if the event or service is ongoing, or if a "manifest injustice" would occur. In such cases, Congress may override the waiver by joint resolution within 60 days.