The problem with angel investing

(this is an audio interview with Maia Heymann from Common Angels in Boston)

She's been investing in tech companies for 20+ years as a VC, angel and tech banker in Boston and Palo Alto. She hates the term "angel" because it doesn't imply that these folks should be returns-oriented.

What do you think? Is this a mis-leading term? Does it imply a gift?