There no law that says a husband and wife have to be buried next to each other. In fact, I don’t always assume that both members of a couple were laid to rest in the same cemetery.
They could have died in separate locations decades apart and taking the one who died last “back” for a burial may not have been feasible.
The surviving spouse in the couple may have married again and been buried with the subsequent spouse. One spouse could have been married to a previous spouse with whom they are buried.
The couple may have eventually divorced or simply separated and, for obvious reasons were not buried together.
The spouses may be buried next to each other but, for some reason, there is no record for one of them indicating where they are buried.
There may be a separate reason that I forgot.
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Through a postage mark on a letter, I located an missing ancestor’s son in Oklahoma. My grandmother and I made a road trip to that town, located the cemetery where he was buried, and hit another mystery. Per the cemetery records, he had three plots. One with a large tombstone for him, one with a simple stone that said Matt, and one unmarked. His plot was obvious with the large tombstone (he died of old age). The one marked Matt was the nickname he called his wife (who died first) but on the records, the only thing written for the third plot was “wife”. But Matt WAS his wife…was there a mixup of some type? Why the third plot?
Several years later, I found a marriage record for him that indicated he married shortly before he died. I suspect the additional wife was to help take care of him in exchange for his Civil War pension! Whatever the reason, he died within the year and she was likely buried in the third plot.