I've never had a problem getting a wrench on the starter bolts on a full size Dodge truck. 87-96 Dakota's not so bad , I only have had problems getting to that bolt on 318/360 Durango's for some reason. Fortunately I haven't had to do so as much on those as the older ones.
I had an 89 diplomat that I had to replace the trans on, and I got the bolts out of the starter fine but that thing had the starter "grow" to the trans. I had to way-lay on that one with a sledge to break it free. I ended up having to replace the starter because of that one that trans job
I put the old starter back in but it didn't work after having to be pummeled on to get out.