Shh! Don't tell all those guys winning matches with 2.7 of BE in .38 Spl! Or the fans of BE, WST, HP-38/WW-231, and Titegroup in Bullseye matches--those are shot at 25 and 50 yards, btw.
Or how about .32 S&W Long, used for NRA centerfire? You betcha--those guys are using fast powders: N310, Titegroup, and Bullseye, all in minuscule charges between 1 and 2 grains. And you can bet that if filling the case made a difference, those guys would bust out the dippers and trickle chargers to use Clays or TB.
There's a big difference between loading for a rifle cartridge with rifle powder, and a handgun cartridge with handgun powder. Pressure differences caused by powder position are accentuated by the significantly slower burning rate of rifle powder, not to mention the volume and size of rifle cartridges.
Are there handgun cartridges which benefit from the use of a deliberately "fluffy" powder? Sure. .45 Colt comes to mind, as do most cartridges originally developed for black powder. Particularly when loading for cowboy action shooting.
.38 Spl is not one of those cartridges.
If you insist on loading light in that cartridge, and want to use TB or Tin Star, fine--more of the good stuff for the rest of us.
If you want to erroneously suggest that case fill in handgun cartridges is necessary to achieving accuracy or consistent function, i will disagree.