I just came back from Denver, where I did a site visit (5 hotels in 2 days) for my professional organization's 2015 conference. I traveled with my Ristretto (iPad inside, plus many TB smaller pouches) and my TriStar (with my clothing, plus my MBP 13" in a Cache in the middle compartment, plus cables in a Snake Charmer-also in middle compartment, 311 items in a 3D clear cube, Kit, you get the idea).
And I had to board a Canadair (sp) Jet, and had to gate check my TriStar (at United's request). Only as we were backing out from the gate did it hit me that my fairly new MBP was in that gate-checked TriStar...
I kept calm and thought, well, that Cache is well padded, and I have clothing on one side, papers and the Snake Charmer keeping the Cache stable in the middle, plus shoes and other soft goods on the other side.
Didn't check until I got home, and I'm typing away on my safe and stable MBP now.
So I wouldn't recommend gate checking the bag your laptop is in, but know if it's in a TB Cache, tucked in a well padded TriStar, at least one person had a good outcome.