Orchard vs. Grove

A quick dictionary search gave me the same definition for both orchard and grove. I usually know which one to use in a given situation, but I had no idea how to explain the difference to my mother when she casually asked on a walk this morning. Are they interchangable terms or are could they be as different as apples and oranges?

-wm

Merriam Webster indicates a difference:

The primary meaning of grove is any kind of small woodland, not necessarily planted by people (although it can be). Orchard definitely means an agricultural, deliberately planted patch of trees.