Depending on your use-case, you could actually perform hot upgrades with Docker containers. After all, we’re still using OTP Releases, just packaged inside of a Docker container. I just wouldn’t recommend it because I find stateless deployments preferable. So instead you’d typically use techniques like blue-green deployment.
However, the use of Docker makes it extremely easy to deploy and orchestrate Elixir applications on PaaS systems which might be more important for some users.