I think that depends where the house is located. My garage's two outside walls (not counting the front with the doors) are finished and insulated, but only marginally so -- fossil fuels were cheap when it was built in the mid-sixties, and over-sized furnaces were the norm.
My house is made with 2x4 framing and poorly installed, kraft-faced, three-inch fiberglass batts were the extent of the insulation anywhere in the house (including the attic). I've insulated the attic to R-40 and changed all windows and doors -- including in the garage. My next big project is adding insulation to exterior walls, and in the garage that means stripping out the wallboard and adding adding an inner 2x3 frame to the walls to bring them up to R-20 or more.