I think what they are referring to is not to tow the vehicle with the rear wheels off the ground using a tow truck or a dolly, which may well mean not to tow it backwards 4 down either.
I would doubt it has anything to do with backing up a few feet if you are towing 4 down (given all the known challenges to that....). Think about it, if you hook up on any sort of incline, when you put the drive train in tow mode, the Jeep rolls backward (just fine) a foot or so until the tow bars stop it.
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D&S
2015 Tiffin Allegro 31SA; 24k chassis, Sumo springs
2015 Jeep Cherokee Trailhawk
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