Set Condition:
WARNING: This page is about a different car, the 2012 Dodge Durango. However, it is still accessible from the selected car via links, so may be relevant.
When the Power Liftgate Module senses no current on the (Q88) Liftgate Open Driver circuit and no liftgate movement, this code will set. It is also possible for this code to set if the liftgate has been run several times and the internal circuit breaker (Thermo Protection Device) has opened up.