Well, everyone has their opinions but we would always sleeve for a JK with 37s that'll see dirt time. Yup, if you trophy truck it it'll bend at the pumpkin, but if you don't go full retard on the fast stuff, c gussets and sleeves will keep your axle straight. A truss will take you a little further, but it becomes a diminishing return for the money. We also like the JKS front rack bar brace on top of a sleeve kit for the housing.
Another must for 37s is axle shafts. Sure, a lot of guys wheel without them and with feather light throttle application they'll hold together, but sometimes you have to nail it to get somewhere and some upgraded axles will allow you to mash on it here and there without worrying about it. Same goes for the rear. Eventually it'll go.
The last thing to think about is your choice in gears for a 37. As far as performance a 5.13 is the best choice, but a 4.88 is stronger. The pinion on 5.13 and lower gears gets pretty small.
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