European Jeeps are weird and irrelevant. So yes. :POf course, you mean American Rubicons. Euro models do, indeed, have a Rock-Trac/Selec-Trac hybrid standard.
But realistically it wouldn't surprise me if it happened if the market seemed to want it. But a full time case goes against the purpose of a Rubi in the first place, which was the hard core offroad package. Full time cases are weaker, and a great for crappy road conditions, but generally not as much for rock crawling.