I don't think that makes it a bad cartridge, just dishonest marketing.
I think that's the source of a lot of apparent disagreement here, but it shouldn't be. We should all try to recognize when we're being sold BS for profit.
I have been reading Elmer Keith's Rifles for Large Game, and that's essentially what he says about energy numbers, too. Contrary to what people think about the guy, he actually is not an opinionated "my way or the highway" old fool. In many cases, he talks about different sides to an issue. However, he is adamant that energy numbers are used dishonestly by marketers to make cartridges sound like what they're not.
I don't think that's changed in the 70 years since he wrote it.
I can't carry anything smaller than a .38 Special or .380 ACP by policy anyway
Is that a law where you live?
I quite enjoy packing a Mini Revolver, sometimes. I'm glad I live here.