Temper??
Most copper alloys, including brass, achieves it's strength level through cold working, in the case of Rifle Brass, in the drawing proccess.
At that point, it is as strong as it will ever be. You can soften it, and make it more ductile, by annealing it with heat.
Not sure what you mean by tempering, which is a proccess used in alloy steels, (and other ferrous based metals) to achieve a certain level of strength properties after hardenning.
Anyway, NEVER subject the back half portion of a case to any appreciable heat heat, as you would have done in an oven. That is where maximum strength is needed........jackie