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According to the 1885 Winchester catalog, No 10 shells less than 2 5/8 length were available at customer specified length, in case lots, at no extra charge.
One ounce of shot in a ten was an upland load in that time; the short shells may have been for that purpose. The "standard" 2 5/8 inch No10 case would just hold 1 1/4 ounce with a thin wad; black and bulk smokeless required a lot of case volume.
Brass Shot Shells
Threaded Mode