Definitely could be... I think it was my buff Orpingtons as the guilty culprit this evening. They are the only ones who venture that far and there was chicken poop on the far side of the hoop house so it's not a stretch to think they sauntered over to that side of the garden. However I've noticed the straw tossed about even when the chickens have been locked in so I know it isn't just them.The robins.
I had to replant about half a dozen seedlings that they pulled out of the ground in their Scratch-fest. Hopefully they will recover!