Why can't the magic wand select text while the "select - same.." menu command can?

I have always found it iritating, as I'm sure many of us have, that the magic wand will not select text. When it is necessary to select text and objects with the same fill color I choose from the menu "Select - Same Fill Color" which works fine. Is anyone able to explain why the Magic Wand set to Fill Color does not mirror the functionality of Select - Same Fill Color? Thanks!