Here are some comments by Dr. Gary Roberts, a leading wound ballistician:

If you are an LE officer, carry a BUG!!!

While both the .380 ACP and .38 sp can obviously be lethal; the .38 sp is more likely to incapacitate an attacker when used in a BUG role.
BUG--Infrequently used, but when needed, it must be 100% reliable because of the extreme emergency situation the user is dealing with. Generally secreted in pockets, ankle holsters, body armor holsters, etc... Often covered in lint, grime, and gunk. By their very nature, usually applied to the opponent in an up close and personal encounter, many times involving contact shots. A small .38 sp revolver is more reliable in these situations than a small .380 ACP pistol, especially with contact shots or if fired from a pocket.

The Gold Dot 135 gr +P JHP offers the most reliable expansion we have seen from a .38 sp 2� BUG.

.38 Sp Speer 135 gr +P JHP Gold Dot (53921), ave vel=856f/s
BG: pen=13.1�, RD=0.56�, RW=134.5gr
4 layer denim: pen=13.6�, RD=0.53�, RW=134.1gr
auto windshield: pen=9.4�, RD=0.51�, RW=129.6gr

Downside is the appreciable recoil and relatively poor intermediate barrier performance.

There have been many reports in the scientific literature, by Dr. Fackler and others, recommending the 158 gr +P LSWCHP as offering adequate performance. Please put this in context for the time that these papers were written in the late 1980's and early 1990's--no denim testing was being performed at that time, no robust expanding JHP's, like the Barnes XPB, Federal Tactical & HST, Speer Gold Dot, or Win Ranger Talon existed. In the proper historical perspective, the 158 gr +P LSWCHP fired out 3-4" barrel revolvers was one of the best rounds available--and it is still a viable choice, as long as you understand its characteristics.

While oversimplified, bare gelatin gives information about best case performance, while 4 layer denim provides data on worst case performance--in reality, the actual performance may be somewhere in between. The four layer denim test is NOT designed to simulate any type of clothing--it is simply an engineering test to assess the ability of a projectile to resist plugging and robustly expand. FWIW, one of the senior engineers at a very respected handgun ammunition manufacturer recently commented that bullets that do well in 4 layer denim
testing have invariably worked well in actual officer involved shooting incidents.
With few exceptions, such as the Speer 135 gr +P JHP and Barnes XPB, the vast majority of .38 Sp JHP's fail to expand when fired from 2" barrels in the 4 layer denim test. Many of the lighter JHP's demonstrate overexpansion and insufficient penetration in bare gel testing. Also, the harsher recoil of the +P loads in lightweight J-frames tends to minimize practice efforts and decrease accuracy for many officers. The 158 gr +P LSWCHP offers adequate penetration, however in a 2" revolver the 158gr +P LSWCHP does not reliably expand. If it fails to expand, it will produce less wound trauma than a WC. Target wadcutters offer good
penetration, cut tissue efficiently, and have relatively mild recoil. With wadcutters harder alloys and sharper leading edges are the way to go. Wadcutters perform exactly the same in both bare and 4 layer denim covered gel when fired from a 2" J-frame. For example, the Win 148 gr LWC: VEL = 657 f/s, PEN = 20"+, RD = 0.36", RL = 0.64", RW = 147.4 gr
When faced with too little penetration, as is common with lightweight .38 Sp JHP loads or too much penetration like with the wadcutters, then go with penetration. Agencies around here have used the Winchester 148 gr standard pressure lead target wadcutter (X38SMRP), as well as the Federal (GM38A) version--both work. A sharper edged wadcutter would even be better... Dr. Fackler has written in Fackler ML: "The Full Wadcutter--An Extremely Effective
Bullet Design", Wound Ballistics Review. 4(2):6-7, Fall 1999)

So to summarize, something like the Speer Gold Dot is best for tissue damage, but you pay the price in recoil and controllability. Wadcutters do less damage but also have significantly less recoil and thus faster for follow-up. You pays your money and you takes your choice. Either may have a different impact point than standard 158 gr which most snubbies are regulated for.