Some electricians install these outlets upside down as a visual cue that they function differently from standard ones. However, this is a convention, not a rule.
There is no national electrical code requiring a specific orientation. That means the way outlets are installed can vary depending on the electrician, region, or builder preference.
Because of that, an upside-down outlet doesn’t always mean it is switched. In some homes, it’s simply a stylistic choice or part of local building habits.
The only reliable way to know how an outlet is wired is to test it. Plugging in a lamp and trying nearby switches will quickly reveal whether it is controlled or always powered.
What looks unusual at first is often just a practical wiring choice, reflecting convenience, flexibility, or installer preference rather than an error.