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).[2]
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).
