Greg the general requirement is to feed the refrigeration from the small appliance branch circuit look at the last part of 210.52(B)(1).
2002 NEC
210.52(B)(1) Receptacle Outlets Served. In the kitchen, pantry, breakfast room, dining room, or similar area of a dwelling unit, the two or more 20-ampere small-appliance branch circuits required by 210.11(C)(1) shall serve all receptacle outlets covered by 210.52(A) and (C) and receptacle outlets for refrigeration equipment.
Then comes the 'shall be permitted exception'.
210.52(B)(1)Exception No. 2: The receptacle outlet for refrigeration equipment shall be permitted to be supplied from an individual branch circuit rated 15 amperes or greater.
So the refrigerator is either on one of the small-appliance branch or it shall be on an individual branch circuit rated 15 amperes or greater.
No other options, at this point with the lower draw of refrigerators it may be overkill. IMO
Bob
