TT #360 · Parashas Shoftim · Seventh Aliyah · Passuk 21:03
And it shall be, the city nearest to the slain person – the elders of that city shall take a heifer of the herd that has not been worked and that has not drawn a yoke.
Torah Temimah points to Sotah 46a.
TT lemma: אֲשֶׁר לֹא עֻבַּד בָּהּ אֲשֶׁר לֹא מָשְׁכָה בְּעֹל.
English: ‘That has not been worked and that has not drawn a yoke’ – two conditions.
Derash on the double requirement (Bavli) — freedom from work and from the yoke are both necessary.
The heifer must satisfy both: it has never been worked and has never drawn a yoke.