A wheel with any amount of spokes could be trouble if not built properly. That said, I think 36 spokes in a 26" wheel are overkill. Yes, if all else is equal, 36 spokes will be stronger but Nancy and I have been using old Mavic rims and 32 spokes with high load weights and haven't had any problems yet. Go with the wheels that are built best.
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Cheers,
Ron
Wasatch Mountain Range, Utah