I have never had a gate checked bag where you don’t pick up your bag at baggage claim except for regional flights on small planes where even standard carry ons won’t fit in the overhead.

And for the pedantic really small planes like Sansa in Costs Rica for their 30 minute flights between San Jose and other cities.

I've seen everything from gate-checks on the carousel to a special pickup counter to leaving the bag on the tarmac covered in ice, with standard commercial airframes. It depends on airline policy and available airport infrastructure.