A compound when it is tetrahedral it implies that sp3 hybridization is there. Which means that the last d-orbital is not empty because if it was then instead of sp3 dsp2 would have been followed and the compound would have been square planar instead of tetrahedral.
Now the low spin complexes are formed when a strong field ligands forms a bond with the metal or metal ion. The strong field ligands invariably cause pairing of electron and thus it makes some in most cases the last d-orbital empty and thus tetrahedral is not formed.
But it is not absolute for example in tetracarbonyl nickel it is a low spin and tetrahedral but yes undoubtedly they are rare because of opposing conditions in their formation.