I do expert testimony and this guy sounds like a nut. There is no requirement fo put a freezer on a GFI. You would not want to do this for fear of a power outage and the freeezer defrosting. From what you have posted there must be a lot more to this that what you have said. I would like to know how it was determined that the water leaked into the outlet. Check out the freezer itself. It may be defective and caused an overload.
Also check out why the breaker did not trip.
You did not say whether the outlet box was metal or plastic. It would be more likely that an arc may have started the fire. Anyway I think your expert is nuts.

[This message has been edited by Bob (edited 03-02-2002).]