There is not really enough information in the article for me to guess if it could have or should have been found with a search back to patent/land grant.  In addition, I only have knowledge of the situation here in Ohio.  In our state, family cemeteries are an interesting thing to deal with.  With rural land, we always check the cemetery records and/or look at the old maps on acreage properties that have been in the family for some time.
The article makes mention of a seperate deed for the cemetery.  Without researching the property, I would question the reporter's use of the word "deed".  Too make a guess, I would think there was a transfer made subject to the rights of the family to access to the cemetery, or perhaps a licence was filed.  I am basing this guess on the supposition that there is no seperate tax parcel for the cemetery.