@CO17Forester the gear oil would come pouring out the fill plug as soon as you started moving. It doesn't take much RPM to get the gear oil climbing all over the place. It won't be "dry", unless it has set for hours.
If you have seen any video of how those aftermarket differential covers impact oil flow in a rear differential, it wouldn't matter much where a sensor was placed if it was monitoring temperature. Gear oil is slung everywhere in very heavy amounts.
It's no different than having a temperature sensor and inch above the oil level in an engine. It's going to get coated with hot oil. It may not be perfect but its still going to work effectively.
It would only matter if the car was not in motion at all. If there is very little movement, it wouldn't need to be monitored...
But once it is up to significant temperature, about everything in the dff is also there. It is a pretty compact piece, so it's not like there is enough distance for major temperature differences.