If you've ever read Jeep Owner's Manual instructions for flat towing, they will generally tell you to put the transfer case in neutral , and the transmission in park if you have an automatic, or in gear or if you have a manual transmission. Many vehicles with manual transmissions will tell you that if you are flat towing, you should remove the rear driveshaft, or for a 4WD, place the transfer case in neutral. Most transfer cases will oil properly regardless of gear selection. The same cannot be said for many manual and automatic transmissions. Check your owner's manual before flat towing to ensure that you don't cause internal damage to your tranny or reputation.