Energy which does not damage tissue is not meaningful.
Well, that is a reasonable assumption. But it may not be true.
Just as many have taken to the assumption that 12 inches is the right "minimum" penetration, they have taken to the assumption that a handgun round with a large "energy dump" will not stop an attacker any better than a round penetrating the same amount with a small energy dump. But we don't know that.
Recall that the majority of assailants stopped by hangun fire don't die, and so were stopped by something other than a fatal wound. So, while we know that penetration of vital organs is needed for fatal stops, we do not know all the factors that influence the non-fatal stops (sometimes called "psychological stops") that apparently accout for most stops.
Hence you can choose a bullet that penetrates 8” but if it hits along the periphery of the body it, too, may “over-penetrate”.
That doesn't change the fact that a bullet that penetrates 18 inches in gel can be expected to overpenetrate more frequently (and with greater residual velocity) than a round that penetrates 11 or 12 inches.
Again, these days it's a bit of an anachronism, supposing we must choose between a low-energy dump round that penetrates 18 inches or more, and a high-energy dump round that penetrates only 8 inches. We can have both energy dump and penetration.
For example, there's the
.40 S&W 125gr Barnes Tac-XP, which can apparently be pushed to over 1400 fps and yet seems to still penetrate just shy of 18 inches in gel. And typical "bad ammunition" (like the infamous Hornady Critical Defense 9mm) actually penetrates 11 inches, just shy of "acceptable."
It's perhaps worth remembering, too, that the most common "bullet failure" in ammo tests is an HP that clogs with barrier material (like denim or gypsum), fails to expand, and then acts more like FMJ than an HP. So in use, the penetration of anything except the "latest and greatest" HPs may actually be greater than advertised (if clothing or other barrier is encountered).