Yeah good point, the axle tubes are bigger on the JK, not sure about the actual housing. I think that the pinion/yoke/carrier is interchangable between the JK and XJ D44's, so the depth might be the same?
Also I have a transfer case drop that is probably permanent because the nutserts were rotted out, and there was some welding needed. So sitting in the normal position, the diff pinion is only a few inches lower than the xfer case shaft, and the xfer case shaft is almost pointed directly at the rear diff, just a little high. So the slip yoke didn't have much shaft left to compress with the D35 on, and the D44 pinion is even closer.
I have even considered going SOA in the rear only with stock YJ leafs, to get more clearance and lift. But then you have the axle wrap issue to think about.
1995 YJ "Mabel", 2.5L Muncie SM465 np231j 4.88's HP30 Lockright JK 44 Detroit 33s CJ clip
Actually, it's pronounced "mill-e-wah-que" which is Algonquin for "the good land."