Is there a code requiring a water shut off valve to be behind a refrigerator with an ice maker/water dispenser? This pertains to New York State ( Rockland County).
Yes. Sort of. It doesn't require it to be behind the fridge, but it does require one on the supply.
Uniform Plumbing Code
606.5 Control Valves. A control valve shall be installed ahead of each water-supplied appliance and immediately ahead of each slip joint or appliance supply.
Unless your county has amended the code.