Yah... could be; probably was local code. All I remember is wiring
kitchens was a real bitch cause of all the different dedicated circuits
you had to run for DW/Disposal, and appliances. I always hated
stringing 12 ga wire. Always got along real well with 14 ga; but 12 ga
and higher always ****ed me off. Except for 8 ga copper to the stove..
it always went in no problem.

One time I was in this SEVERLY HIGH END residential remodel job... some
freaking mansion from like 1920 that was being updated, and whoever
roughed the kitchen in ran 10 ga to an appliance outlet, but left the
old box in place, and the box was like 1/4 deep, or so it seemed, and I
was futzing with it and futzing with it and then I started cussing at
it and finally just got completely ****ed and jammed everything in, and
put the cover plate on, and it looked like complete hell cause the
outlet was crooked and also was not flush; and I turned around and
walked straight into the owner who had been watching me the whole time.
Ah, memories.