What trim level? Sport/Overland or Rubicon? Rubicon has higher fenders for more clearance. But I don't think any trim levels fit a 37 without a little rubbing from what I've seen.
I was able to put 37s on my Mojave for a week while waiting for my lift to come in. I didn’t get any rub with aftermarket wheels at 4.6” of backspace but I would never wheel it like that.