It will be detirmined by what size and design of wheel you are looking at. The JK already sits pretty wide so I don't think you would want to go too wide. Most people do just enough to clear everything. I personally have 15" steel wheels so that required me to go with at least 4" to clear the calipers but I wouldn't think you would need to go any wider then 3.75 or 3.5 at the max. I belive 17" steel wheels you can be down to the 5" range. I think stock are only something like 6.5 so people are running spacers to fit wider tires or they will rub. So I guess the important question now would be what size/style/type wheel where you thinking about?
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