I dunno. How much of today's bloated federal government can be justified as "necessary and proper" for exercising its enumerated powers---even under Hamilton's broad reading of "necessary and proper"?
Jefferson didn't seem to see limit the possible power of the Federal government if "convenient" qualified as "necessary":
"If has been urged that a bank will give great facility or convenience in the collection of taxes, Suppose this were true: yet the Constitution allows only the means which are "necessary," not those which are merely "convenient" for effecting the enumerated powers. If such a latitude of construction be allowed to this phrase as to give any non-enumerated power, it will go to everyone, for there is not one which ingenuity may not torture into a convenience in some instance or other, to some one of so long a list of enumerated powers. It would swallow up all the delegated powers, and reduce the whole to one power, as before observed. Therefore it was that the Constitution restrained them to the necessary means, that is to say, to those means without which the grant of power would be nugatory."
As for the the Supreme Court, its usual approach is to limit the power of Congress only where legislation impacts upon a specific Constitutional prohibition (e.g., the Bill of Rights).