Example case which does away with the need for fans is:
https://www.amazon.com/Geekworm-Raspberry-Computer-Aluminum-...
https://www.amazon.com/Geekworm-Raspberry-Computer-Aluminum-...
https://flirc.tv/more/raspberry-pi-4-case https://flirc.tv/more/raspberry-pi-case (for RPi 2 and 3)
https://www.waveshare.com/pi4-case-argon-one.htm
Edit to add the fan is optional, so it can run fanless with no throttling.
Admittedly, that's a simple load, but my Pi never gets over 42 degrees C, in a tropical area, averaging around 30 degrees C.