Deputy Southampton coroner Graham Denson made the comments during an inquest into a crash on the A338 at Breamore that killed a mum-of-two, Linda Williams.
He recorded a verdict of unlawful death after her partner, Michael Stewart, who was driving the Vauxhall Astra, was convicted in June for causing death by dangerous driving.
Stewart had his legs crossed to relieve back problems when he ploughed into the back of a lorry stopped behind a car turning into a lay-by.
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It emerged during the hearing the driver in front of the lorry, Jacqueline Parker, from Fordingbridge, had stopped her Landrover Freelander to pull in after her mobile phone rang.
The lorry driver driving behind, Alan Bromley, was on the phone shortly before ramming his brakes on to avoid crashing into the Freelander.
And Deborah Walker, driving behind the ill-fated Astra, was found to have sent a text shortly before the collision ahead of her, which she avoided just in time.
Ms Williams, 61, of Uphill, Weston- Super-Mare, a front seat passenger, was killed instantly.
A trial in June heard how Mr Stewart had not been able to untangle his legs in time to brake properly.