A few times I've read that people think that when checking the tranny fluid level it will vary if it's in Park or in Neutral.
I wondered about this when I was trying to get my head around what goes on
With the 545/45 RFE it's not the case. The fluid level will be the same both in Park and Neutral.
The fluid flow schematic below shows nothing is different for Park-Neutral. The only difference being that when in Park the mechanical pawl is engaged. The fluid flow route does change in Neutral over 8Mph, but no one checks fluid level in a rolling Jeep
For safety reasons, Park is the obvious go-to position to have the tranny in to check the level.
Below is a schematic of it in First, it's actually highly doubtful, after seing all the internals, that the ATF fluid height would alter enough then either for the average checker, when stationery.
The different veins in the valve body are always full but not always under pressure, and minimal volume of the clutch piston drums changing isn't significant enough. Keep in mind while looking at the schematics that the dark filled-in lines represent routes under 'pressure', it doesn't indicate those lines/veins/chanels are full when black, empty when white.
Their might be a slight change in height, but not huge.
Not as big of a difference to matter to the ATF pick up, as would travelling near your Jeeps roll over point, or traversing steep hills.
After all that crap, short version...
Just check the level in Park.