I agree that it's probably not as critical as some would make it sound, but then again, if I'm going to try to beat someone senseless, I'm going to grab a baseball bat and not a pair of chopsticks. There are far more cases of a .22 or .25 round getting caught up in multiple layers of clothing compared to .40 or .45.
If you put any stock in the FBI penetration testing, there seems to be a big difference between ".380 ACP and larger" and "everything smaller". There's even a pretty fair jump between .380 ACP and 9mm. So all else being equal, I'd probably consider one of those rounds as my minimum for a SD gun.
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