The New Rubicon Comes with 4.10s & 32" tires with that 202HP Minivan engine in it & It does fine off road.
My Opinion is that if you do a lot of driving in the Hills (Off road) 4.56s for anything over 31"
If you are going to stay with 31"s (Highly UNlikely, You will get the 32" or 33" bug sooner or later) 4.10S ARE GREAT!
I would feel comfortable running 32"s with no ill effects with 4.10s., I do not like the idea of spinning the 4.0 up too high for too long!
Remember Just my opinion, There are many on this board!