One may drag a bed, chair, or bench on the ground, since it is not certain that doing so will make a furrow. Even if the item could easily be lifted off the ground, thus avoiding the possibility of creating a furrow, it may still be dragged on the ground. As long as the person dragging the item does not intend to make a furrow, and there is no certainty that one will be formed, this is permitted, as it is considered a davar she-eino mitkaven (SA 337:1). However, if it is certain that a furrow will be made, one may not drag the item, as it constitutes Ĥoresh. Even if one does not intend to plant there, making the land cultivatable is in fact an act of Ĥoresh (via the principle of psik reisha; see above 9:5).
In an area with an eruv, one may push a baby carriage or stroller even if it is clear that the wheels will make grooves in the dirt. This is because the wheels do not dig in and loosen the earth as a plow does. Rather, they pack down the earth, which actually does not effectively prepare it for sowing or planting. One may even pivot in the dirt with the carriage, because even then it is not certain that earth will be turned over and prepared for planting (SSK 28:48; Yeĥaveh Da’at 2:52).
. Davar she-eino mitkaven refers to a case where it is not certain that a melakha will be performed. It is permitted in accordance with the opinion of R. Shimon in Shabbat 22a. However, if it is certain that a melakha will be performed, it is considered a psik reisha, which R. Shimon agrees is prohibited (Shabbat 103a; MT 1:5-6). According to most poskim, psik reisha is prohibited even when the melakha performed is rabbinic. Their proof for this is derived from the prohibition on dragging. Even though the furrow is made with a shinui and not by an instrument normally used to plow, it is still prohibited (Shabbat 46b). Others maintain that making a furrow by dragging a heavy object over the ground is prohibited by Torah law, because it is not considered a shinui. Rather, it is extremely similar to the classic way of plowing. This is the opinion of Rabbeinu Tam and R. Avraham ben Ha-Rambam. See Menuĥat Ahava 2:1:6. If a furrow would actually be detrimental to the yard, it would seem that one may drag items, as the action would be considered a psik reisha de-lo niĥa lei in a case of a double rabbinic prohibition (according to many), since the furrow is made in a way that is irregular as well as destructive. See above, ch. 9 n. 2.