I have learned from this site that the garage must have a gfi outlet however, as you mentioned, you don't want to trip the outlet when it involves a fridge.
Also, as I recall, the "readily accessible" clause went out the window as my thread specifically mentioned ceiling outlets for garage door openers and it was decided that even that outlet had to be gfi.
However, if it were me, I'd say screw the gfi when using it just for a fridge and this would be against code.
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