I think that would be the only reason not to use .38Spl brass but, it still going to get dirty, especially if you are shooting lead.
I use to load my target loads in .357Mag brass because they produced tighter groups (less travel before contacting forcing cone??) but stopped doing that.
I use the .38Spl brass for my plinker loads and save the .357Mag brass for my magnum loads
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