At stations where there is a requirement that bags fly with the passenger, this is a non-issue if there is a VDB before the hold is loaded. Once the hold is loaded and DL has a choice, there is a preference not to pull luggage, but it happens sometimes, so it can be case-by-case (bad pun).
There are no VDB rules, so agents have a great deal of discretion. Solo passengers, single segment, no checked bags, easy to rebook = easy VDB.