  We present new Jansky Very Large Array observations of five pre-Swift
gamma-ray bursts for which an ultraluminous (SFR > 100 M_sun/yr) dusty host
galaxy had previously been inferred from radio or submillimetre observations
taken within a few years after the burst. In four of the five cases we no
longer detect any source at the host location to limits much fainter than the
original observations, ruling out the existence of an ultraluminous galaxy
hosting any of these GRBs. We continue to detect a source at the position of
GRB 980703, but it is much fainter than it was a decade ago and the inferred
radio star-formation rate (~80 M_sun) is relatively modest. The radio
flattening at 200-1000 days observed in the light curve of this GRB may have
been caused by a decelerating counterjet oriented 180 degrees away from the
viewer, although an unjetted wind model can also explain the data. Our results
eliminate all well-established pre-Swift ULIRG hosts, and all cases for which
an unobscured GRB was found in a galaxy dominated by heavily-obscured
star-formation. When GRBs do occur in ULIRGs the afterglow is almost always
observed to be heavily obscured, consistent with the large dust opacities and
high dust covering fractions characteristic of these systems.
