I swear on my Apple ][ (which had the stiffer spring under reset) you had to press ctrl at the same time. Mine had an after-marked Videx keyboard controller though, and maybe that was a feature of that controller?
There is a switch on the keyboard interface card inside the ][+ that allows you to toggle between requiring CTRL be held down, or just pushing the reset key.
I would assume that this was added later, and wasn't available on the earlier models.