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Yes absolutely. Illegal and marginally unsafe. No argument. But likely he'd live to tell about it. But not dangerous to the point of fantasy like towing it unbraked. This variant is highly likely to end badly.

You're out of your mind. No, seriously. Don't even consider it. Towing an unbraked 22,000lb vehicle with a 7500lb vehicle will end badly. None of that weight will transfer to the towed vehicle. You'll have the same amount of traction that you do empty, but a whole lot more momentum. You'll...