This started in the early 1990s when I worked for an electrical-supplies wholesaler, and I think some localities might require it. The reason is that a stainless-steel receptacle wall plate could come loose and slide down to contact the two live prongs. Most houses use plastic wall plates, but stainless versions are common in commercial applications.I've seen it as well, not just GFIs. There are some things out there that aren't code but some in the trade think are best practice. I have an electrician friend that insists receptacles should be mounted neutral or ground up in the event something metal falls down and gets wedged between a plug and the receptacle. I tell him he's nuts and it sets him off.