If you have an automatic you really want to be as accurate as possible. The 'running' diameter of the tires is them on the ground. Probably measure all four add that up and then divide by four for the best result. If you are off it will mess up your shift points.The important figure is the unloaded diameter of the tire. It might be more accurate to measure your spare if the tires really are 35 inches in diameter. The real measurement that counts in calulating speed is the circumference of the tire rather than the diameter. You'ld be travelling about 3% faster than your speedometer tells you I think. Probably not enough to worry about, except where your mileage is concerned. It would be better than you thought.
If you have a manual it is not as important. However, set it correctly so you know the mileage on the vehicle. My TJ had the wrong gear (TJs use a gear in the transfer case to set the speedometer) for who knows how long. I also have no idea how long the 33" tires have been on it so I don't know what the actual mileage is on that vehicle. It could be well over 10,000 miles off. They originally came with 27 -28 inch tires.
Set your speedometer!!