The Sahara comes with a D30 front, and can't even be ordered with a rear locker as an option like the X version can.
The ONLY JK that can be ordered with a front D44 is the Rubicon.
You CAN order the F/R D44's with lockers and 4.10 ratios separately from Mopar though...but, if you wanted a front D44, and were buying a new JK, it would make more sense to just order a Rubicon at that point.
That said, the new HD D30's are probably strong enough to wheel 37's as discussed, as long as you are not too yee ha on the skinny pedal. Smooth drivers can regularly get away with that, not so smooth drivers will even break D44's with 31's....etc.
The gearing is also an issue....as going from a Sahara's std 32's to 37's will DROP your rpm about 13.5%....and a Sahara's stock gearing is 3.21....
...the Rubi's stock gearing is 4.10.
Going from 3.21's to 4.10's RAISES your rpm by ~ 28%
In other words...a 4.10 Rubi running 37's is STILL effectively geared lower than a 3.21 Sahara running 32's.
I'd like to point out that running 37's involves a crossing over in rolling resistance....35's don't make an enormous difference over the stock 32's, but 37's DO....so that extra gearing is doing a lot of extra work as well...which is why many re-gear for 37's, but most do not for 35's (Some want to re-gear period, of course, as lower is better off road, etc...)
Food for thought.