While talking to Rob at Willy's Works here in Tucson. He said that CJ's are getting used and are so old the indexing hole in the bell housings are becoming warn in an egg shape. When installing a starter, before the bolts are in place, make sure there isn't any movement in the starter. It should index in the hole and have no slop or movement.
Why does this happen? All it's life the started is under pressure to move AWAY from the ring gear, eventually opening the hole. This might not be the problem at all, but it's something to look for. How do you fix the problem? I really don't know, a machinist could weld a heavy bead in the index hole then machine to match the original.