Do yours do this? I thought it was cute when i brought them home and the roo had his wing over one of them in the box. But i got rid of the roo a few weeks ago and I find it interesting that the 2 hens do this. They both do it. In the photo, the dominant one who has pecked the other's head bald is actually the one underneath, acting like a baby. She came up from behind, squiggling under the other hen as I pretended not to watch.
Following...I’ve wondered the same thing several times as I watched my girls make an incredible effort to be the one/ones at the BOTTOM of the pile! I get having your instincts tell you that a predator would have to “dig deeper” to get to the bottom, but It seems awful hot & uncomfortable right now to want (in South Louisiana anyways) to be under 11 other hens!