Wranglers are often lifted via the aftermarket, and I bet a lot of people who do that don't ever stop to consider whether the headlights need to be realigned after.
My experience has been all Wranglers unless they have aftermarket "eyelids". I think their stock lights have zero angle and just blast straight ahead without pointing towards the ground. Most high intensity lights tend to point at the ground so you don't usually get it straight into your eyes.