Not easily: if it's enforced client side it may as well not exist, if it's enforced server side you just let anyone lock anyone else out of their account by running a constant brute force attack against their account (a DoS vuln). It also does nothing for attackers who try a giant list of accounts but only one or two passwords for each.

I worked on Google's system for solving this. It's a pretty sophisticated analysis that decides whether to demand CAPTCHAs or not based on a lot of factors. The CAPTCHA was needed (at that time) because it's the only way to slow down the attacker without bothering the real user, who won't be shown one.