Are these code references from 2005 and different from 2002? They don't seem real relevant to the issue. To me, the problem lies in 334.14(B) Exposed Work, Protection from physical damage, and 300.4 (which covers some of the protection issues).

What is subject to physical damage is up to the inspector to determine. I too have seen many garages wired with NM run between the studs with no further protection from damage (but these were installed 20 to 30 years ago).


Mark
Kent, WA