Depends, if someone updates their iPhone while they need it badly it's partly their own stupidity, people should always update when at home when they can acces a computer/update when you don't need your iPhone badly.
Their own stupidity? There is no disclaimer by Apple that says to update at home near a computer. In fact Apple is trying to phase out laptops with iPad pros. So this nonsense that you should be home near a computer when updating is just that, nonsense.