OP, you have to play the tech deduction game. There are many possibilities... any of which could be the culprit. As with any mysterious tech issue, you have to try to narrow in on where the problem lies. Ideas you could try:
- Do you happen to have a second AppleTV in your home not yet updated? If so, slug it in place of the first one for a while to see if your core hypothesis- that the update- is behind this.
- I can't remember if this is STILL possible, but if downgrading an AppleTV can be done (reset to factory?), perhaps you can roll it back and then see if the stuttering actually does show via a prior version of tvOS. My guess is that this is no longer possible but if it is and if your guess is right, that might be a way back.
- Isolate the wifi by temporarily connecting with Ethernet. Yes, it may not be fun to run an ethernet cable from router to AppleTV... but this is not permanent, just temporary. The goal: see if it is the wifi signal. If things are fine via ethernet, you will know you have some wifi variability. If you happen to have a mesh system, put one of the SATTs near AppleTV and establish the ethernet connection from the SATT.
- Very carefully track WHEN this occurs. Is it a certain time of day? Is there times of day where all is just fine. Is it when most people are at home and perhaps also using wifi? There's only so much wifi pie to go around. When there are too many people taking simultaneous bites of your wifi, you can easily run short.
- Take careful note of WHAT you are watching. What video format? What audio format? Any consistency between what you watch and this stuttering?
- Are you in a dense wifi zone such as an apartment building? Lots of competition wifi sources can interfere with each other at times, even more so when lots of people are home and using their wifi too. Sometimes, the remedy here can be to change a channel if not reposition your own router or AppleTV.
- Old router? Using crowded spectrum? Maybe it's time for an up-to-date router that uses new standards with less competition from neighbors?
- Can you adjust position or distance between AppleTV and router? Anything between the two that can be causing interference. I recall some early wifi that could be hampered by using an appliance between router and device. I can't remember if that was microwave or garage door or maybe ceiling fan.
- Next time(s) it stutters, immediately run speedtest (app) to see your broadband speed at that time. You may find out that the source of the signal is highly variable. I notice this myself at times... even though I generally have VERY FAST broadband most of the time.
- Less likely: do you have good cables between TV and AppleTV? If you have a spare, you might swap in the spare the next time it is stuttering and then continue watching the same thing. I've seen tales of pets chewing on a cable and the owner doesn't even know until he/she checks their cabling.