Just a random thought here, but it's always bothered me that TPGs don't slab the 1932 Washington Quarters with commemorative labels that say "200th Year of Washington's Birth" or the like. The 1932 quarter was released as a circulating commemorative, period. That the same design was later reused for non-commemorative coinage starting in 1934 has no bearing on the 1932. It's a different type starting in 1934.
My impression is that this is a grey area. The mint system was ready to give up on the Standing Liberty design because of all the problems they had with striking it. In truth, the only reason to mint quarters in 1932 was Washington's 200th birthday. The economy was so bad that they were not needed. That was why none were made in 1933.
I think it should count as a commemorative. I learned about it from this thread by @Beefer518 https://www.cointalk.com/threads/old-commemorative-series-my-digital-album.303934/
