Not in the 2008 code. There is an exception that allows it to be on
it's own circuit but article 210.50(B)(1) specifically includes
refrigeration equipment to be included in the two 20A branch
circuits. Exception #2 under that article allows refrigeration
equipment to be supplied from an individual branch circuit rated at
15A or greater. Since it is not a counter top outlet, it is exempt
from being GFCI protected.

Nate

wrote:

Fridge MUST be dedicated circuit by code - and does NOT need to be
gfci (being a motor - should not be GFCI)