Just wanted to post my experiences:
I wanted to get my friend an iPhone 5 for his birthday and it seemed like the only way to get one in a timely manner was through the online reservation system. I looked through the forums here and saw some members had some luck reserving an iPhone 5 online by creating an AT&T account and walking in the store the next day. I wanted the device only so I could gift it to him. I asked one of the guys in the Apple store if I could get the device and return it and buy it as device only. In the Boca Raton store a week ago, i asked an employee if I could do this and he said it wouldn't be a problem, so when I went to the Palm Beach Gardens store to pick up my iPhone 5, I thought it wouldn't be a problem there either. But to my surprise, they said their policy was that the phone needed to be activated before I left the store and that it was a new policy they implemented to reduce fraudulent resellers. They would not let me buy it as device only.
Long story short, those trying to get the device-only through the reservation system by receiving the phone, returning it right after and purchasing it again as device only aren't going to have any luck as of late.