This was discussed due to garage door receptacles and gfci in the ceilings. Way back when gfci was required in garages there was an exemption above a certain height 6' 8 ". In 08 that changed, the ceiling receptacles are required to be gfci.
There was an exception for single outlets. That changed too. Not sure when.
In 2011 the device reset had to be readily accessible or downstream from the ceiling outlet.
Some folks use a gfci blank and install it near the opener. Others put a breaker in the panel.
Not all jurisdictions adopted this code section. Some don't know the code rule. Others just don't care. In these areas it's still very common to see a gfci and the reset in a ceiling.
If you have to stand on a stool. It's not "readily accessible"'