Mice love romex, and covered up you can't see the problem. A house is usually more mouse proof, and if there is a mouse problem, you are more motivated to fix it, so not as big an issue. I have found it difficult to mouse proof an overhead door. Conduit makes it easier to add on or make changes in the future. This may be a 'here" thing too, but if it has a vehicle door in it, the outlets have to be ground fault.I expect it is due to vehicles tracking in snow or rain water making it a potential wet location. That was code "here" all the way back in 2002 when I built my shop, as is the disconnect on incoming power, even if another disconnect is in view. I learned of both of those on initial inspection. I had to add the disconnect but had only one outlet installed at the time so that was easy to fix and then I knew how to proceed.
Got my curiosity up and had to Google code on GFCIs in garages. It's been NEC code since at least 2008, maybe since 1978. Exceptions for dedicated appliances such as freezers.