I think both Darryl and Bryce are right given the circumstances. I ran an early Bronco D44 with 35's and stock axles/joints. I could wheel all day long without breaking but I found myself having to be careful, because if I got a tire in the air and I was still under power, I would break a joint or shaft. If I was quick enough to get off the throttle I could save it. But, since I "like" to use my horsepower, I found it to be a bit of a nusiance. So, I upgraded to alloy shafts and super joints. Over the next 2 years, I NEVER broke anything in my front axle. I switched to 37's (measuring 36") and still did fine.
So, when I decided to do my linked suspension and go full width, I opted to go with a HPD44 Ford axle. I had it sitting in the garage ready to start building. We went to the Unlimited open house & Bryce was there with his tracker. True 37" stickie Trepadore tire. He got it twisted between 2 logs and with a simple burp of the throttle, he broke an alloy outer shaft. It got me to thinking that if Bryce could break an alloy shaft in a parking lot, is this what I want to base my build around? I opted to build a D60. I am absolutely positive that I have less money in my 60 than what I would have had in a blinged out 44 and I have beat the snot out of it with no problems. I've never had a problem hanging it up. I find a front dif is pretty easy to work around obstacles, it's usually the rear that is more likely to hang up.
So to the point, can a person wheel a D44 with 37's successfully? Yes, but you will eat u-joints over time and you will break if you run it hard. If you are a mild wheeler and work at being cautious, it will survive just fine.