OK, so it might not have prevented the submarining in this case, but...
It would require an awfully strong side guard structure to withstand the highway speed right angle impact of a heavy low slung automobile.
I checked how strong they're supposed to be. Per
89/297/EEC, the side guards are required to be "capable of withstanding a horizontal static force of 1 kN applied perpendicularly to any part of its external surface...".
...the sudden deceleration of the car from highway speed to stopped would be similar to head on collision
Granted, but the crumple zones on the car are probably better than the crumple zones on a human head.
The fatality may have still occurred given the speed involved.
The statement from Tesla states:
Had the Model S impacted the front or rear of the trailer, even at high speed, its advanced crash safety system would likely have prevented serious injury...
Even if this particular crash wouldn't have been mitigated by the side-guards, that's no reason
not to fit them.
Edited: Tesla claim it would likely not have been fatal