Arlington House, The Robert E. Lee Memorial
By early 1864, the military cemeteries of Washington, D.C., and Alexandria, Virginia, were rapidly filling with war dead. Quartermaster General of the United States Army Montgomery C. Meigs proposed using of the Arlington estate as a cemetery. United States Secretary of War Edwin M. Stanton approved the establishment of a military cemetery on June 15, 1864, creating Arlington National Cemetery. 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.
Navy Annex
A 1998 Congressional proposal to expand Arlington National Cemetery onto land that the Navy Annex and Fort Myer then occupied led to concerns that Arlington County officials had not been properly consulted, leading to the withdrawal of the proposal. However, the National Defense Authorization Act for Fiscal Year 2000 (Public Law 106-65), which was enacted into law during October 1999, subsequently required the Secretary of Defense to transfer to the Secretary of the Army administrative jurisdiction of the Navy Annex property. The Act required the Secretary of Defense to demolish the Annex's buildings and prepare the property for use as part of the Cemetery, while requiring the Secretary of the Army to incorporate the Annex property into the Cemetery.