Probably confusion with the allowable taps for 'outlets' in Exception 1 of 210.19.(4) and also shown in table 210.24. If I understand this correctly, in a 20A (or even a 30A) circuit, you are allowed to have 14ga tap wires to an 'outlet'...but the outlet must _not_ be a receptacle outlet.

This makes sense since many outlets are fixed known loads, but receptacle outlets have the capability of being loaded until the breaker trips.

-Jon