I guess it just depends on the dog (size, temperament, &c) and how far you are going. I wouldn't want to keep a large dog cooped up back there for more than a few minutes but a mini/toy might have enough room for a cross-country trip.
My ACD is rather high-strung and, even though she would fit, she wouldn't be (mentally) comfortable. Plus, I can't think of a good way to get her back there without scratching the paint or interior. The ACD I had back around the turn of the century was much calmer and would probably have done just fine.
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