The act of urinating in bushes after dark. The phrase is attributable to the R.E.M. song of the same name, written after the band was driving in a van after a show in the early 1980's and directed the van's driver, drummer Bill Berry, to pull to the side of the road so that the other band members could engage in some "night gardening" on the roadside bushes.
The cops gave him a ticket because he was caught gardening at night over off Broad Street.