Ryan,
That garage recptacle, has been in my mine for many years too. When I worked for my old boss (1975-1984) We were always told to keep those receptacles above 24". When I was in my own business ( 1984-1998 ) I almost always did it the same way. ( Force of habit.) I have been looking for a code section ( NEC, BOCA, IMC, NFPA, Etc.) maybe I am missing something.