Jeep 2010 Grand Cherokee - Owner Manual - Manual (Page 361)

If the transmission is not operable, or the vehicle must be
towed faster than 30 mph (48 km/h) or farther than
15 miles (24 km), remove the driveshaft or tow with all
four wheels OFF the ground. Acceptable methods are to
tow the vehicle on a flatbed, or with one end of the
vehicle raised and the other end on a towing dolly. Four-Wheel Drive Models Only
The manufacturer requires towing your vehicle with all
four wheels OFF the ground using a flatbed.
CAUTION!
Towing this vehicle using any other method could
result in extensive damage to the transfer case and/or
transmission. Such damage is not covered by the
New Vehicle Limited Warranty.
360 WHAT TO DO IN EMERGENCIES