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.
Arlington National Cemetery
On September 23, 1996, the National Defense Authorization Act for Fiscal Year 1997 (Public Law 104-201) authorized the Secretary of the Interior to transfer to the Secretary of the Army all of the land in Section 29 that was within an "Arlington National Cemetery Interment Zone" and some of the land in the Section that was within a "Robert E. Lee Memorial Preservation Zone".