Not only are fresh Ubuntus a bit touchy, but upgrading in-place has bitten me badly in the past. It's always a clean-slate install for me now.
Do you have a tendency to make system changes that get in the way of the upgrades? (i.e., where has it gotten stuck for you before?)
That being said, I've not given it a fair try for a few releases, so it's possible that in-place upgrades are better tested now, but I don't see the point of taking the risk. If it goes wrong, I'll end up reimaging anyway, so why waste the time?