The stock location for the spare tire will certainly fit up to a 32 inch tire (I have tested with a 32x11.5x15 BFG MT tire). You will need to modify the length and angle of the mounting bolt, but the tire fits without touching the rear hatch or the seatback. By looking at it, I would guess you may even be able to fit a small 33 inch tire back there as well.

I hope to have pictures and the mounting modifications up as soon as I get the tire in there.

If anyone has more information or pictures, please contact josh@jeepzj.com

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