Mo' articulation, mo better? I mean there's no reason why you couldn't do 31s and 3 inch lift.
I almost feel like we are chasing the wrong rabbit when it comes to ride height because suspension travel is the more important thing to analyze. You could use for example the Rancho Rs55239 with a 2.5 inch lift, or with a 3.5 inch lift. The 3.5 inch lift results in roughly 5.25 uptravel and 4.25 down, the 2.5 I think would be the inverse of that.
There are many rabbits to chase, some of which are often ignored by most. If we disregard ground clearance provided by tires, a 100% stock TJ Rubicon with an automatic transmission will significantly out perform the typical TJ 35" tire build with open diffs and a manual.