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.
Confederate Memorial (Arlington National Cemetery)
After the process of informing families ended, reburials began in April 1901 and were completed the following October. It is unclear how many Confederate dead were disinterred and reburied in the new Confederate section. In 1912, the House Committee on Appropriations observed that legal authority existed for interment of 264 Confederate soldiers—128 of which came from the Soldiers' Home National Cemetery and 136 of which came from Arlington National Cemetery. More modern sources provide different numbers, however. One historian says just 128 bodies were reinterred, although the majority of sources say 264 or 267 bodies were reburied. Other sources pin the number of reinterrments at 265, 409, 482, and 500 bodies. Discrepancies may be attributable to a law, the Act of August 24, 1912 (37 Stat. 440), which permitted any Confederate veteran living in or near Washington, D.C., to be buried in the Confederate section at Arlington.