Daniel, that's something I've wondered about, whether freshly harvested seeds still contain enough moisture for chilling to work. When I tested it but only on a very small scale because I could only find one pod at the time, the seeds I tried were still dormant as far as I remember - I'd have to try and find my notes on that or try it again. But you also have to separate that from the seeds not having seed dormancy in the first place.
Whether they have seed dormancy may depend on your climate and other factors. In other words, as @admmad
has said, the same cross may have seed dormancy for some people but not others depending on the environment experienced by the pod parent. If the seeds don't have seed dormancy they will germinate well and promptly without stratification so in that case they'd be germinating despite rather than because of any refrigeration.
I know that the seeds I have tested here have seed dormancy because the un-stratified group would germinate about about 25% within a couple of weeks whereas when stratified first they would germinate at 90+%. They key to determining if they have seed dormancy is how quickly your seeds germinate without prior damp (not wet) chilling.