As of 2014 all refrigerators must be on a GFCI protected circuit and it must be readily accessible. If you wire the refrigerator on a 15 amp circuit using AWG #14 wire it must be on a dedicated GFCI protected circuit, no exceptions. As you will normally mount the outlet behind the refrigerator you would have to move the unit to reset the breaker if and when it tripped. I would wire the refrigerator on one of the 20 amp kitchen counter-top circuits that is GFCI protected. Now, my answer may be debatable but from how I read the NEC code you can wire it to one of the kitchen branch circuits as long as the refrigerator does not pull more than 16 amps. You might want to check with your local inspector to get his opinion as he is the one who will have the final say.
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