Part of it is training (tip the gun barrel up so the cases can slide out under gravity) and part of it is rough chamber walls. Once the ejector gets the cases moving, they should all fall out of the cylinder without any problem. Proper habits can be acquired through training, and rough cylinder walls can be polished. It's really not that big of a deal.
If you point the gun barrel down, then no, the ejector on the 2.5" barreled guns isn't long enough to get the cases lifted completely out of the cylinder and the cases will just fall back into the cylinder when the ejector is released. Of course, even on longer barreled guns when the ejector can lift the cases totally free of the cylinder, the cases can still just fall back into the cylinder when the ejector is released if the gun barrel is pointing down.
