Could it be a matter of perspective?
"With a muzzle velocity of 1,275 fps, the new 180-grain ... shoots flat and packs a powerful punch... the load gives hunters the power to take down deer, bears or hogs."
https://federalpremium.com/news/news...nd=5&year=2014
At first reading, I would not blame you for thinking the quote above could have been from an 1881 circular for the new 180 grain load, introduced in that year, for the 38 WCF. Paired with a Winchester 73 rifle of course!
Most rifle aficionados would be quick to paint a 38-40 rifle as marginal for deer hunting. On the other hand, todays handgun hunters consider the 10mm to be a perfectly adequate deer hunting cartridge. The reality is a 19th century 38-40 black powder cartridge rifle and a modern 10mm handgun fire the same weight and diameter bullet at about the same velocity. Both firearms strike the same blow!