Chris,
Read this thread from yesterday and a few days ago, it covers your question exactly.
Switched Outlet w/out GFCI under sink
Originally Posted by
Jerry Peck
No - go to NEC 210.8 (A) (6) Kitchens — where the receptacles are installed to serve the countertop surfaces.
Those, and only those, receptacles in kitchens are required to have GFCI protection (admittedly, though, that covers 'almost all' of the receptacles in kitchens).