except by agents." Like the majority, the dissenters also provided a lengthy history of the right of sovereign immunity, but underscoring the uniform inviolability of the right. Citing United States v. Clarke, 33 U.S. 436 (1834), the dissent reasserted that a lawsuit against the United States must be brought under the explicit authority of an act of Congress or the courts have no jurisdiction over it. Gray also reviewed the authority of private citizens to bring suit in the United States Court of Claims. To permit Lee's suit, Gray argued, would open the United States to a multitude of suits over title to land it held. The cases cited by the majority (such as United States v. Peters, Osborn v. Bank of United States, Meigs v. M'Clung, and Davis v. Gray) were improperly cited, Gray argued, as in each case "either the money was in the personal possession of the defendants and not in the possession of the State, or the suit was to restrain the defendants by injunction from doing acts in violation of the Constitution of the United States." It was one thing for the Court to eject or dispossess officers or agents of the United States from land or funds; such actions, Gray concluded, continued to immunize the United States government from suits. Carr v. United States reaffirmed this principle, he concluded. To blur the distinction between officer and state or to assume or imply it without the state's consent, as the majority does, Gray said, would leave the sovereign immunity right in shambles. Once the United States asserted that it was a party to the case, Gray concluded, the courts had no jurisdiction and should not have heard the case. Once the United States interposed itself between Kaufman and Strong and the plaintiff, the courts should not have ordered trial to proceed against them, either. Because the courts had no jurisdiction, the dissenters refused to address the issue of the validity of the title. Subsequent developments The U.S. government faced the daunting prospect of having to disinter 17,000 bodies and transfer Arlington back to the Lee family. Additionally, much of the estate had been developed into the new Army post of Fort Myer. After several months of difficult negotiations, Lee and the government settled on a sale price of $150,000 ($ in dollars). Congress enacted legislation funding the purchase on March 3, 1883; Lee signed over