Were gfci's required in detached garage built in 2003?
GFCI's in garages have been required for a lot longer than 2003 according to the National Electrical Code. 

From NEC 1999:


  210-8 Ground-Fault Circuit-Interrupter Protection for
  Personnel
  
  (A)(2) Garages, and also accessory buildings that have a floor
  located at or below grade level not intended as habitable rooms and limited to storage areas, work areas, and areas of similar use.


The 2002 Code says the same thing in the same section.

If the garage was built in 2003 it should have had GFCI protection installed for all receptacles.