Spare in the trunk ?

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I understand that trouble is unlikely, but, things happen in wrecks. I have seen unsecured spares do damage to trunks and other items in the car more than once (OK other cars are more likely to sustain damage than the front trunk of a Corvair). I have seen trunks pop open in crashes. One time I saw an unsecured spare 150 feet from the car after a wreck...appeared it was airborne for almost all the distance....Could have killed someone unlucky enough to be there. (This was a very bad wreck that killed both the occupants of the car ). The point is it is very easy to make a bracket to secure it so why not do so out of an abundance of caution.