I subscribe to Active Self Protection that posts 2-3 videos per week of criminal encounters. There is good analysis and commentary.
In the hundreds of videos I've watched, I don't ever recall seeing a bad guy dressed in a heavy winter coat. It restricts movement and agility, two characteristics BGs like to have.
IF one had to shoot a heavily dressed assailant at close range, neck/head/pelvis shots could be a viable option.
I just don't see winter clothing as being the dominant factor in choosing ammo to protect myself, even in a .380.
I also don't buy the over-penetration argument. Any pistol bullet, especially a .380, that is a good hit will not have enough exit energy to do a lot of damage down range.
While at Barnes Bullets a decade ago we fired various pistol rounds through 12" of gel with a chrono placed behind it. No bullet, even fmj, had even half its muzzle velocity remaining. Those HPs that exited did so at <300 fps as I recall.
If you are missing and sending pills down range at full velocity, well, that's different.
The likelihood one will encounter a BG any time any where whose clothing might so alter the effectiveness of carry ammo as to render it ineffective means:
1. You carry the wrong gun and/or
2. Your tactics need improvement
Starting from behind the curve of an attack usually means luck is far less of a factor than skill. When you choose to carry a small/relatively low round count/low velocity/light bullet .380, you had best be very skilled, no matter what ammo you choose.