Early cases were different , let`s say the mid 60s (WAG) the heads of the 38spc mite have even been the ole ballon style with the +p being solid with 357s being even more reinforced.
Modern day, lets say mid 80s to present is probably the same strength , as manufacturing process of the stronger case only would simplify production just varying case lengths for the 38, 38 long ,38spc,360 Dan Wesson, 357magnum & the 357 maximum. Then adjusting powder to saami pressures.
Now ya get into the meat of it when you start comparing domestic to import ammo cases & I`ve found a good bit of difference there, I`d have to check my notes but I remember PMC being the heaviest ,but not necassarialy the strongest.
GP