Unlike what at least 80 series owners experience (I don't know if the 80 is a typical Toyota SFA swaybar design), connected Jeep swaybars mean essentially zero front flex. It would not be unusual to expect what you see in that picture (which still looks Photochopped to me, the shadow on the driver's front tire just looks wrong).
The Rubicon has a push button electronic front swaybar disconnect feature (which if it really works is fantastic because swaybar discos on a flexy front end are a true PITA to get lined back up), but clearly even at that level things are not idiot proof.
It has nothing to do with incline. The swaybar disconnected Jeep four link front end flexes like crazy - you are never going to pick up a tire in a situation like that, particularly with the four door Unlimited wheelbase.