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I've worked on three shootings in which .380 JHPs failed to penetrate adequately. (I'm an appellate lawyer who's worked in some capacity on a couple hundred handgun killing cases.) From what I've seen, I don't like the idea of hollowpoint braking action on such a light, slow bullet. I carry 95-gr Double Tap ball in my .380.
I have seen one case of overpenetration (that hit a bystander) with .380 ball, but this appears to have gone through the first person's leg, not his torso. I've never seen a case (out of a couple dozen) of inadequate penetration with any .380 ball round.
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