"Shelf" in Garden?

Father-in-Law said he wasn't planting anything in his main garden this year because he says it has developed a "shelf" under it (his word). He says the water won't drain out of it so he has to let it sit a year or two before he uses it again. He has always had a friend of his rototill his garden with his compact utility tractor. He hasn't had a plow or disk in it in over 15 years. We have some clay around here.

I have never heard of such a thing as a "shelf" under the garden, nor have I had this problem (I use a 2 bottom plow and disc in my garden). I am an amateur so maybe someone can enlighten me? I am thinking if he were to plow it his problem might be solved.
 

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