Cats love nice soft soil and mulch, and they're creatures of habit. If you can discourage them for a while, they'll find another litter box. Try driving stakes around the perimeter of the garden and stringing nylon fishing line from stake to stake. Keep the line about 6 inches off the ground and criss-cross so there's less than 8 inches between the strands. Cats won't walk very far into the bed - they will be afraid they'll get their legs stuck. Eventually they'll give up and you can remove the barriers.
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