School gardens and garden-based learning, though not new in the landscape of United States public education, have gained great popularity in recent years. Scholars from myriad disciplines have examined school garden programs' impact on outcomes ranging from standardized test scores to childhood obesity. As school gardens become commonplace across the country, scholars and practitioners must ask critical questions about program efficacy, sustainability, educational philosophy, and teaching methods. The public school garden site is a unique environment in which constructivist, non-formal educational philosophies are entangled in the structure of standardized, formal education. To examine these tensions and consider opportunities for student learning and the ongoing evolution of public education, we conducted a qualitative case study of a school garden program transitioning from non-profit to public school district control. We conceptualize the non-profit era of the Midwest Garden Education Project as an example of a non-formal education paradigm, and the school district-funded era as its formal education counterpart. Using the findings that emerged from this research, we argue for public education to embrace non-formal learning in the school garden, and put forth a call for broader legitimation of garden-based learning in curriculum.