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Garden/rural cemeteries were not necessarily outside city limits. When land within a city could be found, the cemetery was enclosed with a wall to give it a garden-like quality. These cemeteries were often not sectarian, nor co-located with a house of worship. Inspired by the English landscape garden movement, they often looked like attractive parks. The first garden/rural cemetery in the United States was Mount Auburn Cemetery near Boston, Massachusetts, founded by the Massachusetts Horticultural Society in 1831.  Following the establishment of Mount Auburn, dozens of other "rural" cemeteries were established in the United States – perhaps in part because of Supreme Court Justice Joseph Story's dedication address – and there were dozens of dedication addresses,  including the famous Gettysburg Address of President Abraham Lincoln.
The cost of building a garden/rural cemetery often meant that only the wealthy could afford burial there. Subsequently, garden/rural cemeteries often feature above-ground monuments and memorials, mausoleums, and columbaria. The excessive filling of rural/garden cemeteries with elaborate above-ground memorials, many of dubious artistic quality or taste, created a backlash which led to the development of the lawn cemetery.
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