An interesting question. The rise of the rudder heel is even more pronounced in galleys with curved sternposts, where the effective rudderpost rake created by the gudgeons is approaching or even exceeding 60 degrees to the horizontal.
For most normal rudders with rakes near vertical, the rudder effectively stalls at about 14-15 degrees, ceasing to act as a foil and beginning to act as a spoiler. It still makes the ship turn, but the excessive drag acts as a brake as well. This can be used effectively in some situations, and can be useful at very low speeds where water flow over the rudder is minimal. There is a nice little book by Larry Mott about historical rudders and their behaviour, from Texas A&M Univeristy Press.
In looking at a number of different historical vessels from the 16th century and later, I noted maximum rudder angles anywhere between 17 and 45 degrees, but most were in the range of 20 to 35 degrees. The limiting factor is usually internal, when the forward end of the helm contacts the inside of the hull or some other obstruction. For example, the maximum rudder angle on Vasa is 23 degrees, limited by the helm meeting a rider futtock (not in any way by the whipstaff).
Fred