Under what conditions might a planet orbiting a red dwarf star NOT be tidally locked?

From what I've read, planets orbiting red dwarf stars would most likely be tidally locked. Under what circumstances might this change? For example, if a planet had been the recipient of some kind of large impact over the course of its existence? We theorize that in the Solar System, Venus's reverse orbit might have been caused by a big impact. If such a thing were to occur on a planet orbiting a red dwarf, could it spin on some kind of "normal" rotational period (e.g., 5-100 hour days).

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Under what conditions might a planet orbiting a red dwarf star NOT be tidally locked?

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