I had my stock (32") spare tire off this weekend to install an antenna mount, and I noticed a crack in my stock carrier on the JKU. The crack is similar to some of the pictures of the cracked stock carrier I've seen on jeep internet forums. Typically these happen when someone puts a 35" tire on the stock carrier and does not adjust the rubber stops that help stabilize the tire on the carrier - there is a gap between the tire and the rear door of the jeep which allows the door/carrier assembly to flex. Eventually either the spot welds in the door, or the carrier, will break. In my case, I installed the teraflex heavy duty door hinge about a year ago. This installation requires the removal of the passenger side tire stop, and I did not fabricate a replacement. So I figure the crack on the carrier started on the passenger side since the driver side still had the stop in place, stabilizing the load on that side of the carrier, while there could be some movement of the tire on the passenger side of the vehicle.
If you are going to run a larger tire, you really need to address the issue of properly supporting the spare so it does not destroy the door or the carrier. One option is a new bumper with a tire swing gate. In my case, I plan on installing the teraflex carrier this weekend. I'll try to post a pic of the cracked carrier after I do the install of the new one. This Teraflex carrier also has some history of failure, and without making a long post that much longer, I'll just say that I think proper support of the spare plays a role.
Bottom line is if you run larger than stock tires on a rear door carrier, it would be a good idea to take the spare off every so often to inspect the carrier. When it's not winter I do this 2-3 times a year when I rotate tires on my JKU. I had the shop do a 5 tire rotation last time I had oil changed a few weeks ago, am surprised I was not advised of the crack.