Sakel (2003:82) notes that there is a tendency that modifiers appear after the head noun with animate heads, and before the head noun with inanimate heads.
Source:
Sakel 2003:11
Legal Values and Meanings:
Value
Meaning
?
Not known
A
adj-N
B
N-adj
C
both orders with neither order dominant
D
both but for specific forms
E
both but depend on the characteristics of the nominal head