Jeep Wrangler 2020 Owner's Manual page 311

NOTE:
If the folding, non-adjustable head restraint interferes with
the installation of the child restraint, the head restraint may
be folded and the child seat installed in front of it (Two-Door
Models).
WARNING!
Always make sure the head restraint is in its upright
position when the seat is to be used by an occupant who
is not in a child restraint. Sitting in a seat with the head
restraint in its lowered position could result in serious
injury or death in a collision.
Car Seat With Head Restraint Folded
1 — Folded Headrest
2 — Child Restraint
SAFETY 309
4