to the best of my knowledge, Alaska is the only major carrier that explicitly allows SDC from a redeye to a flight departing the evening before, but the window is very small ... and based on their schedules, this only really applies to ANC<-->SEA flights as their TCON redeyes (SEA-JFK/BOS, LAX-BWI) are the typical 9-10pm departures
this is from the SDC policy link on the AS website
- For "red-eye" flight departing between 12:00 a.m. and 3:59 a.m., the new desired flight may depart as early as 10:00 p.m. on the day prior to your original departure.