I found an article about the lawyer that was involved in the Chris-Craft "cleat towing" case . . .
David Bianchi
Towards the bottom of the article talks about the Chris craft case.
It was back in 1979 . . . a wooden Chris Craft was towing a sailboat with a bunch of students on it. The cleat being used to tow broke loose and struck one of the occupants of the sailboat. Chris Craft argued that the cleat was not meant for towing, but the lawyer found a previous case involving Chris craft where they indicated that the cleat was adequate for towing. The person was awarded $7.5 MM.
Chris Craft filed for bankruptcy in 1988 after a period of mis-management.
I too would be concerned about towing a boat with inadequate cleats or towing eye. So, anyone who offers to tow another boat should be familiar with the capabilities and limitations of their boat.
Interestingly enough this was my previous boat after we spent a few hours in town sightseeing. . .
Pretty much high and dry as the tide went out (oooppps) . . .
The local harbor master offered to tow us off. He attached a line to the starboard aft cleat. . . . and had to use pretty much most of the 200+ hp of the patrol boat. As he was doing this, I was figuring that there was a pretty good chance that the cleat would either snap or pull out. . . . to my surprise the cleat held up and he pulled the boat into deeper water. Not even a gelcoat crack around the cleat or anything years later.
The cleats on my previous boat and on my current boat are very substantial, thru-bolted, and certainly stronger than the tow eye. So, if I was in a situation where I had to tow, it would be reasonable for me to use the cleats. If I had an economy boat, maybe not.
I think it is a matter of knowing your boat and being safe.