Reference

Judges 3:11

And the land had rest forty years. And Othniel the son of Kenaz died.
9

And when the children of Israel cried unto the Lord, the Lord raised up a deliverer to the children of Israel, who delivered them, even Othniel the son of Kenaz, Caleb’s younger brother.

10

And the Spirit of the Lord came upon him, and he judged Israel, and went out to war: and the Lord delivered Chushan–rishathaim king of Mesopotamia into his hand; and his hand prevailed against Chushan–rishathaim.

11

And the land had rest forty years. And Othniel the son of Kenaz died.

12

And the children of Israel did evil again in the sight of the Lord: and the Lord strengthened Eglon the king of Moab against Israel, because they had done evil in the sight of the Lord.

13

And he gathered unto him the children of Ammon and Amalek, and went and smote Israel, and possessed the city of palm trees.

Counter-Arguments

The strongest case that this verse does not belong in this theme.

Land Sabbath / Rest for the Earth

The verse describes a period of peace for the land following a military victory and the death of a leader, not a deliberate agricultural practice or cyclical rest for the earth as defined by the theme. The "rest" here refers to an absence of war and oppression, not a fallow period for cultivation.