I am surprised by this. I have several recent trips that indicate otherwise. I am religious about the 23:59 check in, this weekend was case in point. We were in Florida on $203 SEA-RSW tickets, I'd be surprised if anyone paid less or was in a lower fare class. There were allegedly 20+ Plats on the flight back and I was #1 on the upgrade list (and in fact got one of the 2 F seats). I gave it up to sit with my wife.
I have been on 5-6 $200 transcons in the last month and used the 23:59 checkin trick and always wound up #1 on the upgrade list for legs that I didnt get an EUA. I find it hard to believe that all the other Plats on these flights (and there were other Plats below me on the waitlist) were bigger cheapskates than me!