Most times this happens when the drivers panic.
I live in Maryland where generally drivers cant handle ice and snow, short creeping their cars at 15 MPH.
I find it very frustrating but its still better than traffic blocking accidents.
People hit those breaks not realizing that the the ability of the car to turn depends on the front wheels rolling along the surface. As soon as a the wheels stop rotating all ability to control direction is lost esp if the wheels are turned too.