In the absence of an affirmative, I'll just say that I did a search of my own.
This site:
lists a bunch of static analysis tools for go.
I wrote a minimal program that has the condition of opening an os.File, which is an os.Closer, and not explicitly closing it. None of them complained about this minimal program, so it is reasonable to assume that none of the static analysis tools on the gometalinter list check for that.