I can't answer your question, but do believe it is really the inspector's call as to what is "not protected".
Where I am they commonly build a detached residential garage with one circuit for a light and receptacle using NM stapled on the inside of the studs. They would not get away with having any NM on the exposed face of the stud because it is "not protected".
On an attached garage, they have to hang the sheetrock for the fire barrier anyway, so they always do the entire garage.





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