Firstly, I am not sure this is the right area for this type of question but alas it is here so here is my comments.
334.10 Uses Permitted. Type NM, Type NMC, and Type
NMS cables shall be permitted to be used in the following:
(1) One- and two-family dwellings.
(2) Multifamily dwellings permitted to be of Types III, IV,
and V construction except as prohibited in 334.12.
(3) Other structures permitted to be of Types III, IV, and V
construction except as prohibited in 334.12. Cables
shall be concealed within walls, floors, or ceilings that
provide a thermal barrier of material that has at least a
15-minute finish rating as identified in listings of firerated
assemblies.
You have other issues as to the NM Cable within the garage ( should we assume you are speaking of a detached garage?) I would tend to think of the following concerns:
334.15(B) Protection from Physical Damage. Cable shall be
protected from physical damage where necessary by rigid
metal conduit, intermediate metal conduit, electrical metallic
tubing, Schedule 80 PVC conduit, or other approved
means. Where passing through a floor, the cable shall be
enclosed in rigid metal conduit, intermediate metal conduit,
electrical metallic tubing, Schedule 80 PVC conduit, or
other approved means extending at least 150 mm (6 in.)
above the floor.
Type NMC cable installed in shallow chases or grooves
in masonry, concrete, or adobe, shall be protected in accordance
with the requirements in 300.4(E) and covered with
plaster, adobe, or similar finish.
So a strong argument that in a garage exposed, the NM Cable would be subject to physical damage due to the general nature of a garage. ( atleast in mine anyway ). Many will say that the detached garage is part of the dwelling unit itself but I would disagree and say it would fall under the guidelines of 334.10(3)
BTW....the madate for GFCI's in garages is because the NEC says to install them in the garage and their is no link to a wet location in that requirement regarding garages and I would not call them a wet location or a damp location for that matter.
My opinion is that NM Cable would be allowed in the detached garage as long as you meet the requirements in 334.10(3) and 334.15(B).